CCPA Addendum

CALIFORNIA PRIVACY PRINCIPLES

 

Unless otherwise defined in this California Privacy Notice (this “Notice”), all terms defined in the Privacy Policy and all other terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) retain the same meaning when used in this Notice.

 

SCOPE

This Notice supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”).

This Notice describes how we collect, use, disclose and otherwise process Personal Information of individual residents of the State of California, within the scope of the CCPA.

 

PERSONAL INFORMATION DISCLOSURES

When we use the term “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household in accordance with the CCPA.

For the purposes of this Notice, Personal Information does not include:

  • De-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you or a particular household.
  • Publicly available information from government records.

 

RECIPIENTS OF PERSONAL INFORMATION

As described further in the “How We Share Your Personal Information” section of the Privacy Policy, we share Personal Information internally and with our service providers that help us operate our Platform and business. We may also share Personal Information with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.

In the last 12 months, we have collected each of the categories of Personal Information noted in the table below and disclosed it, for a business purpose, to the categories of recipients listed below. The table also indicates when we shared the Personal Information to third parties in the last 12 months and the types of third parties.

 

Category of Personal Information Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes Shared with Third Parties Categories of Third Parties to Whom Personal Information is Shared
Biometric Information, such as behavioral characteristics used to identify you; imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings from which an identifier such as a faceprint can be extracted; keystroke patterns or rhythms; gait patterns or rhythms; and sleep, health or other exercise data that contains identifying information. Not Applicable No Not Applicable
Internet/Network Information, such as IP address, Device Information, and Log and Analytics Data. Service Providers Yes Marketing Partners
Geolocation Data, such as Location Information from your device or estimated based on your IP address. Service Providers Yes Marketing Partners
Sensory Information, such as call recordings, or similar information. Service Providers No Not Applicable
Other Personal Information, such as information you information you submit to us. Service Providers Yes Marketing Partners
Inferences, such as predictions about your interests and preferences. Service Providers Yes Marketing Partners
Sensitive Personal Information, such as:  Social Security number; financial account, debit or credit card number. Service Providers No Not Applicable

ITsavvy will not sell, rent or lease your Personal Information to others.

 

We do not use or disclose Sensitive Personal Information outside of the permitted purposes set forth under Section 7027(m) of the California Consumer Privacy Act Regulations.

 

SOURCES OF PERSONAL INFORMATION

As described in the “How We Collect Your Personal Information” section of the Privacy Policy, we collect Personal Information directly from you when you provide it to us, automatically using cookies and other tracking technologies, from the categories of third parties listed in that section and by combining Personal Information we may otherwise obtain.

 

PURPOSES FOR COLLECTING PERSONAL INFORMATION

We collect, share or disclose Personal Information about you for the business and commercial purposes further described in the “How We Use Your Personal Information” section of the Privacy Policy.

 

RETENTION OF PERSONAL INFORMATION

The period for which we retain your Personal Information varies, depending on the type of Personal Information and the purpose for which it was collected.  The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.

 

YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

Right to Know The right to request the following information relating to the Personal Information we have collected about you and disclosed about you:

·         The categories of Personal Information we have collected about you;

·         The categories of sources from which the Personal Information was collected;

·         The business or commercial purposes for collecting, selling, or sharing the Personal Information;

·         The categories of third parties with whom the business shares Personal Information;

·         The categories of Personal Information sold, and for each category identified, the categories of third parties to whom it sold that particular category of Personal Information; and

·         The categories of Personal Information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom it disclosed that particular category of Personal Information.
Right to Access (Right to Know Specific Pieces of Information) / Portability The right to access and obtain a copy of the specific pieces of Personal Information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.
Right to Correct The right to request that we correct your inaccurate Personal Information maintained by us.
Right to Request Deletion The right to request the deletion or erasure of Personal Information we have collected from you, subject to certain exceptions.
Right to Opt Out of Data Sales or Sharing The right to direct us not to sell or share Personal Information we have collected about you to third parties, including for ad targeting/cross contextual advertising.
California’s “Shine the Light” Law California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures.

 

HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

To exercise your rights, you or your authorized agent may submit a request to exercise your rights by emailing us at [email protected] or calling us at 1-630-396-6300 (Monday through Friday, 8:30 AM – 9:00 PM Central). For your security and to ensure unauthorized third parties do not access your Personal Information, we will require you to verify your identity before we can act on your request. If you are a current customer or still have access to your ITsavvy account, you will be required to authenticate through your ITsavvy account. If you do not have an account with us, you will be required to provide an email address and mobile phone number to start the verification process. You may also be required to provide a qualified government-issued photo identification. If you are asking for access on behalf of someone else, we will require verification of your identity, as well as proof of authorization by the individual whose Personal Information you wish to access.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

  • You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:
    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Authorized Agents

If you would like to designate an authorized agent to submit certain requests on your behalf, or if you are an authorized agent of an individual with the right to submit certain requests via an authorized agent and would like to submit a request on behalf of that individual, please send an email to the following email address: [email protected]. If you are the resident, in order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such request. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you are the authorized agent, after you submit the request, and if the request is not subject to an exemption or exception, we will require additional information to verify the identity of the resident, as well as your authority to act on behalf of the resident.

Appeals

If we did not take action on your request, you may have the right to appeal our decision. To submit an appeal, please email us at [email protected]. Please note that an appeal must be submitted within 60 days of your receipt of the notice to take action.

Response Timing and Format
• We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
• If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
• Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
• We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

NONDISCRIMINATION

We do not discriminate against you for requesting any of the rights noted above.  We are permitted to deny or limit your request in accordance with applicable laws.

 

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at [email protected] or by telephone at 1-630-396-6300 (Monday through Friday, 8:30 AM – 9:00 PM Central) or call your dedicated client executive.  You may also write to us at the following address:

 

ITsavvy

Attn:  Privacy Manager

2015 Spring Road, Suite# 300

Oak Brook, IL 60523

Re:  ITsavvy Privacy Policy

 

CHANGES IN POLICY

From time to time, we may change our CCPA Addendum. We will notify you of any material changes to our CCPA Addendum as required by law.  We will also post an updated copy of this CCPA Addendum on our Platform.  Please check our Platform periodically for updates.

 

Last Update Date:  September 13, 2024

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