California Privacy Policy

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS]

CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

Last Modified: 12/30/2019

 

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services.  This Addendum supplements the information in the Privacy Policy.  However, this Addendum is intended solely for, and is applicable only as to, California Consumers:  if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

In the below tables and sections, we describe (as required by the CCPA): 

  1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from,
  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
  3. Our Business Purposes –  our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same.
  4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information: 

  1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

 

Category Categories of Sources
Identifiers, e.g., name; alias; postal address; IP address; telephone number; email address.

·        From data compilers and consumer data resellers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, consumer surveys and survey organizations (“Commercial Data Sources”).

·        Government government entities, including public universities, the U.S. Postal Service, and the US Census Bureau.

·        Operating systems.

Characteristics of protected classifications under California or US law

E.g., race; color; religion; sex/gender; marital status; military or veteran status; national origin; ancestry.

Commercial Data Sources.

Internet or other electronic network activity information

E.g., browsing history; information on a consumer’s interaction with a website.

Operating Systems (e.g., visits to our own website).
Geolocation data Data Compilers.

Education Information

E.g., secondary, college and graduate schools attended, major, school activities, achievements and grade ranges.

Commercial Data Sources (including surveys).   Public Universities.

Inferenced information,

E.g., any of the above information about personal interests or demographics (e.g., income, gender, age or interests).

Data Compilers.

 

  1. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers.  The chart below details how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.   

Category Categories of Third Parties We Share With

 

Whether We “Sold” This Category of Personal Information in the Last 12 Months

 

Identifiers, e.g., name; alias; postal address; IP address; telephone number; email address. Data compilers and consumer data resellers, non-profit organizations – particularly colleges and universities, U.S. military services, consumer goods retailers, businesses related to providing educational and student-related goods and services, other retailers including apparel retailers, content publishers, financial services and institutions, advertising and data platforms, and data analytics providers (Referred to together as “Customer Categories”). Yes
Characteristics of protected classifications under California or US law.  E.g., race; color; religion; sex/gender,  marital status; military or veteran status; national origin; ancestry.  Customer Categories Yes

Education Information,

E.g., secondary, college and graduate schools attended, major, school activities, achievements and grade ranges.

Customer Categories. Yes

Inferenced information,

E.g., any of the above information about personal interests or demographics (e.g., income, gender, age or interests).

Customer Categories Yes

 

We also may share any of the personal information we collect as follows: 

Sharing for Legal Purposes:  In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:  We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.

Aggregate and Deidentified Information.  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).   We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

 

  1. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

 

Generally speaking, we collect and share the Personal Information that we collect for the following purposes, as we also have described in our Privacy Policy: 

 

Our Purposes for collecting, using and sharing Personal Information

Data marketing services, for example:

·       Generally, creating data marketing tools and products for our marketer clients.  This can include our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), and data hygiene services (helping customers to evaluate, validate and correct personal information they hold).

·       Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.

·       Assisting our Clients through our Services to provide their current and prospective customers with better service, improved offerings, and special promotions, for instance, advising on which current or prospective customers are most likely to be interested (or disinterested) in certain offers.

·       Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.

·       Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.

 

Online targeting, for example:

·        Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.

 

Aiding the Public Interest:

Providing data (on a pro bono basis) for purposes of aiding efforts to combat missing and exploited children, and contributing to databases for purposes of same.

Operating our Services, for example: 

·        Improving, testing, updating and verifying our own database.

·        Developing new products.

·        Operating, analyzing, improving, and securing our Services.

 

Other internal purposes, for example:

For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.  We use the information collected from our own website, from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.

 

  1. YOUR CALIFORNIA RIGHTS AND CHOICES 

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.  (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

A. Right to request access to your personal information 

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information.

B. Right to request deletion of your personal information

You may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours.  (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.)  However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.  Additionally, we need certain types of information so that we can provide our Services to you.  If you ask us to delete it, you may no longer be able to access or use our Services.

C. How to exercise your access, opt-out and (if applicable) deletion rights 

California residents may exercise their California privacy rights by sending an email to privacy@cbssearch.net, submitting your request on our Opt Out page, or by contacting us at 816-318-4441.  

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights.  For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.

Once we have verified your identity, we will respond to your request as appropriate: 

  • Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.
  • Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”: because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences.  (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)
  • Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

D. Right to nondiscrimination.

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.   

E. Right to Opt-out of the sale of your personal information.  

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section II of this Addendum, titled “OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION”. 

If you would like to opt out, you may do so as outlined on the Opt Out page

F. Information About Persons Under 16 Years of Age 

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).  

G. Authorized Agents 

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney. 

Consumer Access Request

 

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