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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies to individuals, who reside in the State of California (”consumers” or “you”). We adopt this notice along with the Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

 Information We Collect

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category

Examples

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (from employees—see B), or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A 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. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

C. Commercial information.

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

D. Internet or other electronic network activity.

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

E. Geolocation data.

Physical location or movements.

F. Sensory data.

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

G. Professional or employment-related information.

Current or past job history or performance evaluations.

H. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

I. Inferences drawn from other personal information to create a profile about a consumer.

Profile reflecting a consumer's preferences, behavior.

 

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete on our website.
  • Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers,
  • From Third Parties such as third parties you use to log in to our Services.

 Disclosures of Personal Information for a Business Purpose

We may disclose your Personal Information to a service provider or a third party for a business purpose.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information in our role as a business for a business purpose:

Category A:   Identifiers

Category B:   Personal information categories in Cal. Customer Records statute
Category C:   Commercial information

Category D:   Internet information

Category E:   Geolocation

Category F:   Professional or employment-related information

Category G:  Non-public education information

Category H:   Inferences       

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Advertising networks, internet service providers, data analytics providers, government entities, operation systems and platforms, social networks and consumer data resellers
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

 Sales of Personal Information

In the preceding twelve (12) months, we have sold the following categories of Personal Information for valuable consideration:

Category A:   Identifiers

Category D:   Internet information

Category E:   Geolocation

 

Your Rights and Choices

The CCPA provides consumers (California residents) with 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 from which the Personal Information is collected about you.
  • Our business or commercial purpose for collecting or selling 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 sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 

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 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 rights of other consumers 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 business’ 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.

 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 sending logging into your account or by emailing info@pennyandlee.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 (12 and under).

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 your authority to make the request and confirm the Personal Information relates to you. In some instances, if we cannot verify your identity to provide you access to personal information, you may choose to delete such personal information.

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

Where possible, we will respond to a verifiable consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.

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 Sales Opt-Out and Opt-In Rights (“Do Not Sell My Info”)

You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing info@pennyandlee.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by emailing us at info@pennyandlee.com.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

 Non-Discrimination

We will not discriminate against you for 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 through granting 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.

 

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 Authorized Representative

You may designate an authorized agent to make a request under the CCPA on the consumer’s behalf by emailing us from the email address associated with your account, indicating: your name, the fact that you would like to indicate an authorized agent, the name of your authorized agent, and the email address of your authorized agent.

 

CONTACT US.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

 

I Heart Bestie, Inc. DBA Penny and Lee

2530 Berryessa Rd. #512

San Jose, CA 95132-2903

 

Email: info@pennyandlee.com