Last Updated: March 2020
Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, Personal Information 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, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA.
The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
In the preceding twelve months, we have not sold any California resident’s Personal Information.
|Category||We Collect||We Disclose||We Sell||Categories of Third Parties with Whom We Share Personal Information|
|A. Identifiers Examples: Name, alias, internet protocol address, email address, or other similar identifiers.||Yes||Yes||No||Service Providers|
|B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Examples: Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
|C. Characteristics of Protected Classifications under California or Federal Law||No||N/A||N/A||N/A|
|D. Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric Information||No||N/A||N/A||N/A|
|F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
|G. Geolocation Data||No||N/A||N/A||N/A|
|H. Sensory Information||No||N/A||N/A||N/A|
|I. Professional or employment-related information||No||N/A||N/A||N/A|
|J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)||No||N/A||N/A||N/A|
|K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Use of Personal Information
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
- Providing Services: Providing our services.
- Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
- Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
- Personalization: Personalizing your experience on our services such as presenting tailored content.
- Deidentification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.
- Safety Issues: Responding to trust and safety issues that may arise.
- Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use: Short-term, transient use.
- Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, 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.
- Research: Undertaking internal research for technological development and demonstration.
- Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
- Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.
Collection and Disclosure of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
- You/Your Devices: You or your devices directly.
- Service Providers. Data analytics and other service providers that help us run our Service.
- Government as Legally Required: Government entities.
- Third Parties as Legally Required: Third parties as required by law and similar disclosures.
- Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
- Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with proof of your address, name, and email address registered with us.
Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. Click here to opt out of the sale of your Personal Information.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes.
Submit Requests. To exercise your rights under the CCPA, please send an email via our Contact Information section, or visit our website www.relativeinsight.com.
Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.
Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at firstname.lastname@example.org or write to us at: