California Resident Privacy Notice

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

  • Lawfully made available from government records.
  • Deidentified or aggregated.
  • Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category

We Collect

We Disclose

We Sell

A. Identifiers
 

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes

Yes

No

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

 

Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Yes

Yes

No

C. Characteristics of Protected Classifications under California or Federal Law

 

Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding, or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

Yes

 

Yes

No

D. Commercial Information

 

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

Yes

No

E. Biometric Information

 

Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No

No

No

F. Internet or Other Electronic Network Activity Information

 

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

Yes

Yes

No

G. Geolocation Data

 

Example: Precise physical location.

No

No

No

H. Sensory Information

 

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Yes

Yes

No

I. Professional or Employment-Related Information

 

Examples: Job application or resume information, past and current job history, and job performance information.

Yes

Yes

No

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

 

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.  

No

No

No

K. Inferences Drawn from Personal Information

 

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Yes

No

 

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

  1. Providing Services: Providing our services.
  2. Communicating: Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing customer support.
  3. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
  4. Personalization: Personalizing your experience on our services, such as presenting tailored content.
  5. Facilitating Payments: Facilitating transactions and payments.
  6. Deidentification and Aggregation: Deidentifying and aggregating information collected through our services and using it for lawful purposes.
  7. Job Applications: Processing your job application. 
  8. Safety Issues: Responding to trust and safety issues that may arise.
  9. Compliance: For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  10. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  11. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
  12. Transient Use: Short-term, transient use.
  13. Contracting Vendors: Contracting with vendors and service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytics services, or providing similar services on behalf of the business or service provider.
  14. Research: Undertaking internal research for technological development and demonstration.
  15. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
  16. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
  17. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

 

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

  1. You/Your Devices: You or your devices directly.
  2. Affiliates.
  3. Advertising Networks.
  4. Analytics Providers.
  5. Partners: Business partners.
  6. Public: Publicly accessible sources.

 

Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we disclosed your Personal Information to the following categories of third parties:

  1. Advertising Providers: Advertising technology companies, such as advertising networks.
    • Personal Information we share: Identifiers and Internet or Other Electronic Network Activity Information.
  2. Analytics Providers.
    • Personal Information we share: Identifiers and Internet or Other Electronic Network Activity Information.
  3. Affiliates.
    • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, Professional or Employment-Related Information, and Inferences Drawn from Personal Information.
  4. Vendors: Vendors and service providers.
    • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, and Professional or Employment-Related Information, and Inferences Drawn from Personal Information.
  5. Third Parties as Legally Required: Third parties as required by law and similar disclosures.
    • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, Professional or Employment-Related Information, and Inferences Drawn from Personal Information.
  6. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
    • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, Professional or Employment-Related Information, and Inferences Drawn from Personal Information.
  7. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
    • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Characteristics of Protected Classifications under California or Federal Law, Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, Professional or Employment-Related Information, and Inferences Drawn from Personal Information.

 

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your full name, email address, and phone number, and we will let you know if we need any additional information to verify your request.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please call us at 415.413.0445, send an email to legal@redaptiveinc.com, or visit our website.

Authorizing an Agent. If you are acting as an authorized agent, to make a request to know or delete on behalf of a California resident, please send a written authorization signed by the resident to us via the email or postal address provided in the Contact Information section below. We may also require the resident to verify their identity or confirm that they provided you permission to submit the request.

 

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities please email us at legal@redaptiveinc.com or write to us at 340 Brannan Street, Suite 400, San Francisco, CA 94107.

Last Reviewed and Updated: October 25, 2021