State Private Policies
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law.
Categories of Personal Information Collected and Disclosed
|Category||Examples||Collected by Deduce||Disclosed by Deduce for Business Purposes|
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name||Yes||Yes|
|Audio and Video Recordings or Photos with your likeness (e.g. as collected in video interviews or digital diaries)||No||No|
|Social Security number, driver’s license number, passport number, or other similar identifiers.||No||No|
|B. Customer records information (as described in Cal. Civ. Code § 1798.80(e))||A name, signature, address, telephone number||Yes||Yes|
|Social Security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||No||No|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No||No|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No||No|
|Information about an individual’s interests and interactions with Deduce, our partners, or our customers, including transaction data||Yes||Yes|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No||No|
|F. Internet or other network or device activity||Browsing history, search history, IP addresses, unique device identifiers and metadata||Yes||Yes|
|G. Geolocation data||Information about an individual’s location which may include GPS, Wi-Fi and compass data,||No||No|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Audio or visual recordings and images||No||No|
|I. Professional or Employment-Related Data||Information about an individual’s employment or career history||No||No|
|J. Education Information||Non-public information about an individual’s education history or record||No||No|
|K. Inferences||Inferences about an individual that could be used to create a profile about the individual such as preferences, attitudes, behaviors and characteristics||No||No|
Your Rights And Choices under the CCPA
- 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 for the Personal Information we 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).
- The categories of third parties to whom the consumer’s Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.
- 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 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.
- 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 either:
- Sending an email to [email protected].
- Submit a request through your community.
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 Data. 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.
When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the Personal Information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your Personal Information, we will only complete your request where we are satisfied that we have verified your identity to a reasonably degree of certainty.
- Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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.
We will not discriminate against you for exercising any of your applicable 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.
- Opt Out of the ‘Sale’ of Your Personal Information
As defined under the CCPA, Deduce does not sell your information.