CCPA Appendix
Date last updated: 15 May 2024
This CCPA Appendix complements Privacy Notice and tells you what your rights and our obligations are in relation to the processing of your Personal Data in accordance with the California Consumer Privacy Act (the “CCPA”).
If there is any discrepancy between the terms of this CCPA Appendix and those of Privacy Notice, this CCPA Appendix will prevail.
We may change this CCPA Appendix from time to time. The “Date last updated” mention at the top of this page states when the CCPA Appendix was last updated and any changes will become effective upon our posting of the revised CCPA Appendix to the extent permitted by applicable laws.
Where required by the CCPA or other applicable law, we will request your consent to any such changes. We will provide the revised CCPA Appendix by email or by posting notice of the changes on our website or through any relevant Services.
Please click on the links below for further information on our privacy practices for residents in California:
2. What Personal Data do we collect about you?
3. On which legal basis do we process Personal Data?
4. What are your rights and how can you exercise them?
5. Disclosure of Personal Data
1. What is Personal Data?
For the purposes of this CCPA Appendix, "Personal Data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For example, Personal Data includes, but is not limited to, audio, electronic, visual, thermal, olfactory, or similar information or inferences drawn from other Personal Data to create a profile about you reflecting your preferences, characteristics, psychological trends among other things.
For the purposes of this CCPA Appendix, "Sensitive Personal Data" means (1) personal information that reveals: (A) your social security, driver’s license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation;(D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (F) your genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying you; (B) personal information collected and analyzed concerning your health; and (C) personal information collected and analyzed concerning your sex life or sexual orientation.
2. What Personal Data do we collect about you?
The table below describes the categories of your Personal Data that we may collect, and has collected during the 12-month period prior to the effective date of this CCPA Appendix. We will retain your Personal Data for the period necessary to fulfil the purposes for which it has been collected. This includes the purposes of fulfilling our contract with you, satisfying any legal, regulatory, accounting, reporting obligation we are subject to and the establishment and defense of legal claims.
| Categories of Personal Data collected (as listed in the CCPA) | Examples |
| Identifiers | Your first name, last name, your job title and function, office address, unique personal identifier (device permissions, pixel tag, etc.), online identifier such as IP address, work email address, account name, cookies, etc. |
| Internet or other electronic network activity information | Information collected about your use of this website/service, such as your web browsing history, search history, and usage time |
Business or Commercial Purposes. We may collect or use, or have collected your Personal Data during the 12-month period prior to the effective date of this CCPA Appendix for the following business or commercial purposes. We do not use or disclose your Sensitive Personal Data for purposes other than those specified in CCPA. We do not collect or process your Sensitive Personal Data for the purpose of inferring characteristics about you.
• Provision of services
Categories of Sources. The following is a list of the categories of sources from which your Personal Data was collected during the 12-month period prior to the effective date of this CCPA Appendix:
• Direct collection
3. On which legal basis do we process Personal Data?
We process Personal Data of residents in California in compliance with the CCPA. If we are to use your Personal Data for purposes other than the purposes we notified on or before collecting your Personal Data, we will notify the new purposes to you and obtain your express consent.
4. What are your rights and how can you exercise them?
A. What are your rights?
(1) Your rights under the CCPA include, the right to know about your Personal Data that we collect, use, the right to delete your Personal Data, the right to correct your Personal Data.
(2) We will not unreasonably discriminate against you for exercising the rights such as the right to know about Personal Data information under the CCPA by using methods including but not limited to the following:
B. Exercising your rights (right to know, right to delete, and right to correct)
If you wish to exercise the right to know, the right to delete, or the right to correct under the rights of A(1) above, please contact us by using the following means in addition to the communication means described in Privacy Notice. Upon receiving your request to exercise such rights, we will require you to submit your [name and e-mail address] in order to verify your identity.
We will confirm receipt of your requests to exercise your rights within 10 business days in the same manner in which the request was received and provide information about how we will process the request and the limit of our response. We will respond to requests to know, requests to delete and requests to correct within 45 days, and if we exceed the period, we will notify you and respond within 90 days from the day that we receive the requests. If we cannot verify your requests within the 45-day time period, we may not process your requests.
We will record your requests and store them for 24 months.
If you use an authorized agent to submit a request to know or a request to delete, the authorized agent is required to submit to us a written permission proving the authorized agent is permitted to do so and the authorized agent’s own identity verification document(s).
5. Disclosure of Personal Data
We have not and will not disclose your Personal Data to any third party for a business purpose.
6. Sale of Personal Data
We have not and will not sell your Personal Data to any third party.
For the purposes of this CCPA Appendix, “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to a third party for monetary or other valuable consideration.
7. Share of Personal Data
We have not and will not share your Personal Data with any third party.
For the purposes of this CCPA Appendix, “share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Data by us to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
8. Children’s Personal Data
We do not sell or share Personal Data of anyone under the age of 16.
9. Contact Information
You may contact us with questions or concerns about this CCPA Appendix and your choices and rights under CCPA at: