Last Updated: January 1, 2021
Information We Collect
We collect 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 have collected the following categories of personal information from consumers within the last 12 months:
- Identifiers (including name, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers).
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history).
- Internet or other similar network activity (information regarding a user’s interaction with a website, application, or advertisement).
- Professional or employment-related information (current or past job history or performance evaluations).
- Inferences drawn from other personal information (profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
Subject to applicable law, we may retain your information for as long as needed to provide you products or services that you have requested, comply with our legal obligations, resolve disputes, and enforce our agreements. We may not remove your personal information when there is a legal storage requirement, such as accounting rules or when there are other legal grounds to keep the data, such as an ongoing contractual relationship.
We collect information through various categories of sources. For example, we collect and obtain information:
- You provide, such as when you register for one of our events, contact us, respond to a survey, apply for employment, or sign up for emails or marketing information.
- From affiliated companies.
- Using cookies and automatic collection methods.
Your Rights and Options Regarding Your Information
Access and Correction
California Residents’ Right of Access, Data Portability, and Deletion
California residents 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 for the personal information we collected about you.
- Our business or commercial 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).
- 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 providers 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 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, 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.
If you are a California resident, to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 214-383-7360
- Emailing us at email@example.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.
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. Making a verifiable consumer request does not require you to create an account with us. 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 endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or 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 usable 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.
We will not discriminate against you for exercising any of your personal information rights.
Your California Privacy Rights
Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes (if any) and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, we are permitted to provide a cost-free means to opt out of such sharing.
Since we do not provide your personal information to third parties for their direct marketing purposes, it is not necessary for us to establish this procedure.