Notice Addendum for California Residents

Effective 1/1/2020

Last Reviewed 12/27/2019

This Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) describes our collection and use of Personal Information and supplements the information contained in our Privacy Policy and applies solely to all visitors who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Through our Website and our Customer Experience Program, we collect, and have collected over the past twelve (12) months, information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect the following categories of personal information : A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Category	Applicable Pieces of Personal Information Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, address, telephone number, bank account number, credit card or debit card number (for payment processing). Some personal information included in this category may overlap with other categories.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.	Geographic location (through your IP address)

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

Use Of Personal Information

We may use, “sell” for monetary or other valuable consideration, or disclose and, over the twelve (12) months prior to the effective date of this California Privacy Addendum, we have used or disclosed the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information for technical support, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate access. We may also save your information to facilitate new payments or process refunds. (Categories A, B, D, F)
To provide, support, personalize, and develop our Website, products, and services, including to investigate and address your concerns and monitor and improve our responses and targeted offers and ads through our Website, third-party sites, and via email (with your consent, where required by law). (Categories A, B, D, F)
To create, maintain, customize, and secure your account with us. (Categories A, B, D, G)
To process your requests, purchases, transactions, and payments and prevent transactional fraud. (Categories A, B, D, F, G)
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business. (Categories A, B, D, F, G)
For internal testing, research, analysis, and product development, and to develop, improve, or demonstrate our products and services. (Categories A, B, D, F, G)
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, D, F, G)
As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Categories A, B, D, F, G)
Auditing relating to a current interaction related to your use of our Website and advertising, including, but not limited to, counting advertising impressions to unique visitors, verifying positioning an quality of ad impressions, and auditing compliance with advertising specifications and other standards. (Categories A, F, G)
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. (Categories A, B, D, F, G)
Debugging to identify and repair errors that impair existing intended functionality. (Categories A, B, D, F, G)
Short-term, transient use, provided that we do not disclose the personal information to another third party and it is not used to build a profile about your or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction. (Categories A, B, D, F, G)
Performing services on behalf of the business or service provider, 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 analytic services, or providing similar services on behalf of the business or service provider. (Categories A, B, D, F, G)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase. (Categories A, B, D)
Indirectly from you. For example, from observing your actions on our Website. (Categories D, F)

Sharing Personal Information

We may disclose your personal information to a third party for regulatory purposes. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

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 (see Exercising Access, Data Portability, and Deletion Rights), 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 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). We will not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your personal information, your account, or the security of our systems or networks.
If we disclosed your personal information for a regulatory purspose we will provide you a list identifying the personal information and the personal information category.

Deletion Request Rights

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:

Complete the transaction for which we collected the personal information, provide 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.
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.

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 mark@marksheldon.net.

Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We may request additional information so we may confirm a request to delete your personal information.

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.

Most of the information we collect is as a result of your making an account with us. However, making a verifiable consumer request does not require you to create an account with us or to make the request through an account you may already have. We consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will respond to a verifiable consumer request within ten (10) days of its receipt. We will process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will generally deliver our written response to that account. If you do not have an account with us, we will deliver our written response r 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.

Personal Information Opt Out

To exercise the right to opt-out, you (or your authorized representative) may adjust your cookie preferences by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Websites or other websites. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.

You do not need to create an account with us to exercise your opt-out rights.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

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