RM Acquisition, LLC d/b/a/ Rand McNally (“Rand McNally,” “we,” “us,” or “our”) respects the privacy of our website visitors and our users and customers.
At Rand McNally, your trust and satisfaction is of the utmost importance. Because we respect your privacy, we have instituted policies intended to ensure that your personal information is handled in a safe and responsible manner.
- What information do we collect?
- Posting Content
- Children’s Privacy
- How do we use your information?
- Social Media Plugins
- How do we share your Personal Information?
- How do you know your information is secure?
- Employment/Careers Portal
- Data Transfer/Access Outside of the United States
- Data Retention
- California Residents Privacy Rights Notice
- How can you update your information?
- How to contact us
- Accessibility Notice
What information do we collect?
Personal information does not include your personally identifiable information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing in this sentence being referred to as “De-Identified Personal Information”).
Categories of Personal Information We Collect
We collect the following categories of Personal Information:
|Specific Items of Personal Information
|Professional or Employment Information
Information You Provide to Us
We collect Personal Information that you provide to us. Such information may include name, e-mail address, home and/or billing address, and phone number. Such information may also include information you provide when you make a purchase for a product or service, register your e-mail address, and register a product or software. If you register for our Rand McNally Classroom products and services (also considered part of our “Services”), we will also ask you to provide your school or organization’s name, school district, type of institution, enrollment and your position with that institution. If you have visited our Website before and provided us with your e-mail address, we collect information on what pages you access or visit while on our website.
When you make a purchase on a Rand McNally Website, we ask you for your full name, billing address, telephone number, and e-mail address. If you want your order shipped to someone other than yourself, you will need to provide us the name and address of the recipient.
Information We Collect Through Automatic Data Collection Technologies
Every time you visit a Rand McNally Website, our web server automatically collects the following non-Personal Information: your Internet service provider’s address, the referring URL, pixel tags, information on the pages you access on our website, and other technologies.
Except where required by law, Rand McNally may use non-Personal Information for any purpose. For instances in which Rand McNally is required by law to protect non-Personal Information as if it were Personal Information, then we may only use it as we use Personal Information. Where non-Personal Information is combined with Personal Information, then we will protect all the information as Personal Information.
We use a cookie to help us determine repeat visits to our websites. This cookie may be assigned to any user of our websites. This cookie does not contain any Personal Information, and simply helps us better understand if we are providing services that are valuable to our users. If you delete our cookie but have selected “remember me” in your profile, we will give you a new cookie the next time you log in. If you use our Maps & Directions features, we may store this information in a cookie to allow you to more easily re-use this information. Even without using cookies, you will be able to take advantage of almost all the features on our websites.
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and Internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time spent on our Website, and the pages you viewed while on our Website.
- Behavioral tracking. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website; (c) speed up your searches; and/or (d) recognize you when you return to our Website.
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below:
Cookies (or Browser Cookies)
A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari, or Google Chrome).
Different types of cookies which have different purposes are used on our Website.
These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.
These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font, and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on websites which do not belong to us.
It is possible that you will come across third-party cookies on some pages of websites that are not under our control.
Local Storage Cookies. Certain features of our Website may use locally stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear GIFs, pixel tags, and single-pixel GIFs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking,” a common process which may be used in connection with advertisements on other websites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers automatically record certain log file information reported from your browser when you access the Website or Services. These server logs may include information such as which pages of the Website you visited, your Internet Protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
We also collect information though our Google AdWords tracking code to support advertising by Google AdWords, which collects data about our Website’s traffic via the DoubleClick cookie.
We have implemented Google AdWords features based on Display Advertising, which may include Remarketing, Google Display Network Impressions Reporting, the DoubleClick Campaign Manager Integration, or Google AdWords Demographics and Interest Reporting. We may use Remarketing with Google AdWords to advertise online through third-party vendors, including Google, which may display our ads on websites throughout the Internet. We and our third-party vendors, including Google, may use first-party cookies (such as the Google AdWords cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve advertisements based on your past visits to our Websites, and to report our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services as it relates to visits to our Websites. We may use data from Google’s interest-based advertising or third-party audience data (such as age, gender, and interests) with Google AdWords to, among other things, better provide you with appropriate content.
By using the Ads Setting, you can opt-out of Google AdWords for Display Advertising and customize Google Display Network ads. Please also consult Google AdWords’ currently available opt-outs, and Google’s safeguarding your data webpage, available here.
You may also submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“Posted”) on public areas of the Website, or transmitted to other users of the Website or third-parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons. You agree to and do hereby grant us a royalty-free, sublicensable, transferable, perpetual, irrevocable, non-exclusive, and worldwide right to use, modify, and perform any Content you post to our Website, or that you submit for posting. The term “Use” includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the Content.
We may post Content on our Website you post to our Facebook or other social media account pages.
USER CONTENT POSTING GUIDELINES
To the extent our Website contains areas where you can post or submit to be posted (together “post”) Content such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. By posting any Content you agree to abide by these Content Posting Guidelines. You agree not to post any Content that:
- Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
- Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
- Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
- Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
- Promotes or provides instructional information about illegal or illicit activities;
- Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
- Includes personal or identifying information about another person without that person’s explicit consent;
- Contains software code of any kind, including, but not limited to, code that contain viruses, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person’s computer or network or telecommunications equipment;
- Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
- Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.
You may not attempt to gain unauthorized access to our computer systems or those of any our service providers or third parties, or engage in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of, the Website or our services. We reserve the right, but do not undertake the obligation, to refuse to post or remove any posted Content from our Website for violation of these rules or for any other reason, and to refuse to accept any future postings by you.
By posting any Content you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, modify, aggregate, summarize, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed.
Rand McNally does not solicit Personal Information from anyone under the age of 18 (a “Child”). If a Child submits information to us through any part of our Website, and if we know that the person submitting the information is a Child, we delete the information as soon as we discover it and do not use it for any purpose, nor do we disclose to third parties. If your Child has submitted Personal Information to us and failed to indicate that he/she was under the age of 18, you can request that such information be removed from our customer lists by contacting us using the Contact Us information listed below, and we will honor your request.
While our Rand McNally Classroom product is for use specifically by students, any usage of the product is allowed only with a single, generic, school access password which contains no information which would identify a Child. We only count the number of users by school. We do not collect or store Personal Information on student usage of the Classroom services.
How do we use your information?
- To present our Website and its contents to you.
- To provide you with information on products or services that you request from us.
- To provide you with the services that you have requested.
- To provide you with notices about your account, including expiration and renewal notices.
- To send you emails and newsletters with product, service, company, and other information.
- To provide you with information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
- To respond to your questions or other requests.
- To contact you with regards to the Website.
- To process any applications, changes to your account information.
- To process other information or Personal Information that you submit through this Website.
- To notify you about changes to our Website, our policies, terms, or any products or Services we offer or provide through it.
- To allow you to participate in interactive features on our Website.
- To ask for ratings and reviews of our Website, Services, and/or products.
- To contact you regarding a sweepstakes, contest, or promotion in which you have participated.
- To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.
- To request your participation in surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
- To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, and measuring demographics and interests.
- For internal purposes, such as Website and system administration or internal audits and reviews.
- For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
- To operate, maintain, and provide to you the features and functionality of the Services.
- To notify you of data privacy incidents or provide you with legally required information.
- To fulfill any other purpose for which you provide it.
- In any other way we may describe when you provide the information.
When you supply us with Personal Information to order a product, the information you provide will be added to our customer file (including your name, address, phone number, and e-mail address). You may receive periodic mailings, emails, or telephone contact from us with information on new products and Services, discounts, special promotions, or upcoming events that we offer. If you do not want to receive such mailings from us, then please follow the instructions in the “How To Contact Us” section, listed below.
We may send you emails with information on new products and Services, discounts, special promotions, or upcoming events that are being offered. If you do not wish to receive such emails from us in the future, please locate our contact information in the “How To Contact Us” section listed below in order to remove yourself from our email list, or click on the “opt out” link on any email you receive from us. Please not that when you make a purchase and provide us with your email address, we may send you confirmation of your order via email even if you have chosen to not receive future emails from us about your products and Services. We may also contact you by mail or telephone if we have questions about your order.
Social Media Plugins
We integrate social media application program interfaces or plugins (“Plugins”) from social networks, including Facebook, LinkedIn, Twitter, Instagram, Tumblr, Pinterest, and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site (SMS) login.
For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged onto your Facebook account, you can link the contents of your Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provide of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account before accessing our Website.
How do we share your Personal Information?
- Hosting providers for the secure storage and transmissions of your data.
- Database software providers for the management and tracking of your data.
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants.
- Third-party service providers who send communications on our behalf regarding our products and Services. We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to Personal Information needed to perform their functions, but may not use it for other purposes.
- Payments solution providers, who may perform outreach on our behalf regarding our products and Services.
- Outbound call center providers, who may perform outreach on our behalf regarding our products and Services.
- Fulfillment and shipping vendors for the fulfillment of our products and Services.
- Advertising partners, including social media providers, for the delivery of targeted advertisements.
Disclosures to Service Providers
Disclosure of De-Identified Personal Information
De-Identified Personal Information or non-Personal Information is aggregated for system administration and to monitor usage of the Website. It is utilized to measure the number of visits to our Website, average time spent, number of pages viewed, and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services, and for any other purpose we deem appropriate. We may disclose, sell, rent, etc., your De-Identified Personal Information to third parties and we may receive valuable consideration for doing so.
We will attempt to notify you about these requests unless: (a) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (b) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
Your Consent to Disclosure and Transfer of Your Personal Information
We may buy or sell business assets or be acquired by or acquire other companies. In such transactions, personal information generally is one of the transferred business assets. Your consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. In such case, you agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger, or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent. Please know that if such a transfer takes place, the third party acquiring the information will be advised of your preferences about how we use your information.
Disclosure to Third Party Merchants “Presented by Rand McNally”
Merchants presented on (or that have links from) the Rand McNally Website and those merchants, who send catalogs or host websites “presented by” Rand McNally, have separate privacy policies and data collection practices. We have no control over and therefore no responsibility or liability for these merchants or their policies or practices. For more information regarding merchants who send catalogs or host websites “presented by” Rand McNally and their privacy policies, please see the merchant’s home page or review the customer service section of any catalog you may receive from the merchant.
How do you know your information is secure?
When you see either a solid key icon or a locked padlock icon at the lower portion of your browser window, then your site is secured through Secure Sockets Layer. We use industry-standard encryption technologies when transferring and receiving your information on our Website. If you do not see one of these icons, please contact your Internet service provider. When we transfer and receive certain types of sensitive information, such as financial information, we will redirect you to a secure server and notify you through a pop-up screen on our Website.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain.
Please note that email is not encrypted and is not considered a secure means of transmitting sensitive information, e.g., credit card numbers.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
Collecting Personal Information. In connection with our recruiting and job application process, you may provide personal information to us. We ask for certain data, including educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to submit an application. You also may choose to provide us additional information, such as your CV, resume, and/or transcripts; employment references and related information; and compensation requests. In addition, we may collect information from third parties, for example, in connection with a background or employment check and/or an employment reference.
Sensitive Personal Information. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you have a disability and would like us to consider any accommodation, you may provide that information during the recruiting process.
Voluntary Disclosure. Your provision of personal information in connection with the recruiting or job application process is voluntary, and you determine the extent of the information you provide to us. Please note that if you decide not to provide certain required information, it may affect our ability to consider you for employment.
Use of Personal Information. The information you provide may be used to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements.
Data Recipients and Sharing with Third Parties. We may share your personal information internally and with service providers and other third parties as necessary in connection with recruiting, employment, corporate governance, acquisitions, legal or regulatory requirements, to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes. We require that our service providers and such other third parties keep your personal information confidential and that they only use the personal information in furtherance of the specific purpose for which it was disclosed. We and our service providers may use your personal information in an anonymized format (in a form in which your identity cannot be determined) for other purposes not specified above, including in the development and testing of products and services.
We may employ security procedures at our facilities and on our computer systems to monitor and maintain security, including the use of closed circuit television. Any monitoring of our facilities, systems or assets is performed in accordance with applicable law.
Retention and Access. We may retain your information to consider you for other job opportunities. To the extent permitted or required by law, we may delete data at any time; accordingly, you should retain your own copy of any information you submit to us.
You may access and correct personal information you have submitted online using our careers website. You may submit other requests by mail to the Rand McNally HR Coordinator, P.O. Box 7600, Chicago, IL 60680-9915 .
Your Responsibilities. You are responsible for the information you provide or make available to us, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable.
Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe. As such, we and our Service Providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
We may retain De-Identified Personal Information for as long as we choose.
California Residents Privacy Rights Notice
If you are a resident of California, you have additional rights which are described in this section.
The following in this section applies only to California residents:
Shine the Light Law California Civil Code § 1798.83 (available here)
Under this law, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information (if any) which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom we have shared such information during the immediately preceding calendar year. You also have the right to request that we revise your Personal Information on record. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.>
Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578) (available here)
CalOPPA applies only to companies which collect Personal Information of California residents.
We honor Do Not Track signals, and we do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Users can visit our Website anonymously by adjusting the settings in their browser. We do not allow personalized third-party behaviorial tracking, though we may use De-Identified Personal Information to track users’ click or browsing patters.
California Consumer Privacy Act of 2018 (CCPA) Privacy Notice
Under the CCPA, California residents (“Consumers”) have a number of specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Right
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:
1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
7. Comply with a legal, regulatory or law enforcement obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by: using our webform, or sending an email to us at email@example.com. 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 for access or data portability 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. We will only use Personal Information provided in a verifiable Consumer request to verify the requester’s identity or authority to make the request.
Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).
Webform Verification Method: When you submit a request using our webform we will match the information you submitted with the information we have for you on file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above). We may not be able to comply with your request if (a) we are unable to verify your request, (b) if we are unable to match you with information in our database, or (c) if an exception under the law exists exempting us from complying with your request.
Response Timing and Format
We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) 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 usable 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.
We will not discriminate against you simply for your exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including by refusing to gran discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How Can You Update Your Information?
Through your account settings, you may access and, in some cases, edit or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.
We will evaluate each request and reply as required by applicable law or our policy in an appropriate manner and form of communication that respects the security of the information you have requested.
How To Contact Us
Special Note: When you contact us, please provide us with your exact name and address as it appears on correspondence you have received from us.