Effective: July 1, 2020
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: credit card number and debit card number
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Sensory Information: audio, electronic, olfactory, and similar information
- Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
2. Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you sign up for a subscription
- Your devices, such as when you visit our Site or mobile applications.
- Your family or friends, such as when they provide us with your contact information so we can send information that may interest you, such as gift subscriptions.
- Our affiliates
- Vendors who provide services on our behalf
- Our joint marketing partners
- Online advertising services and advertising networks
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
3. Sale of Personal Information
We do not sell your personal information in exchange for monetary consideration. We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration. We share the categories of personal information listed below for online advertising purposes and to provide third-party social network features and functionality on our Site. You have the right to opt-out of this disclosure of your information, which may be considered a “sale” under California law.
During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information about you to online advertising services and social networks:
- Subscriber names and addresses, on a case-by-case basis for mailings we have approved.
- Online Activity
We do not have actual knowledge that we sell personal information of minors under 16 years of age.
4. Sharing of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.
We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information||Category of Third Party|
|Identifiers||Advertising networks, service providers, joint marketing partners, data analytic providers, government entities, social networks, data brokers and other individuals as you may request or authorize|
|Online Activity||Advertising networks, service providers, joint marketing partners, data analytic providers, government entities, social networks, data brokers and other individuals as you may request or authorize|
|Inferences||Advertising networks, service providers, joint marketing partners, data analytic providers, government entities, social networks, data brokers and other individuals as you may request or authorize|
5. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: email address, mailing address, name or account number. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.