The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it. In the below tables and sections, we describe (as required by the CCPA):
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:
Depending on how you interact with us, [Business] may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.
Category | Sources | Business / Commercial Purposes for Collection |
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Identifiers, e.g., name; postal address; email address; Voter Identification number; or similar identifiers. |
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We collect personal and online identifiers for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We collect personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes. |
Categories of personal information described in Cal. Civ. Code § 1798.80(e). E.g., physical characteristics or description; telephone number;. Information included in this category may be duplicative of information identified in other categories in this Appendix B |
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The personal data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We supply personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes. |
Characteristics of protected classifications under California or US law
E.g., race; color; religion; sex/ gender, gender identity; marital status; military or veteran status; national origin; and ancestry; age. |
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The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes. |
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
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The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes. |
Professional or employment-related information E.g., current or past employment, occupation. |
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The data is used for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We supply such data for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes. |
Generally speaking, we use the Personal Information that we collect for three purposes:
We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers. The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.
Category | Categories of Businesses We Share With | Whether We Sold This Category of Personal Information in the Last 12 Months |
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Identifiers, e.g., name; postal address; email address; Voter Identification number; or similar identifiers | Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors | Yes |
Categories of personal information described in Cal. Civ. Code § 1798.80(e). E.g., physical characteristics or description; telephone number;. Information included in this category may be duplicative of information identified in other categories in this Appendix B |
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors | Yes |
Characteristics of protected classifications under California or US law. E.g., race; color; religion; sex/ gender, gender identity; marital status; military or veteran status; national origin; and ancestry; age |
Political organizations, candidates, organizations which undertake political activities, Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors | Yes |
Commercial or transactions information. E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors | Yes |
Professional or employment-related information. E.g., current or past employment, occupation. |
Political organizations, candidates, organizations which undertake political activities , Government agencies, Advertising firms, analytics service providers, cloud storage providers, marketing service providers or payment processors | Yes |
We also may share any of the personal information we collect as follows:
Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
Generally speaking, we collect and share the Personal Information that we collect for the following purposes:
We collect personal and online identifiers for our business purposes, including: Voter outreach, political speech, internal research, identity verification, internal operations, auditing, debugging, short-term and transient use, fulfilling and improving our services which are described as political and identity verification systems and legal compliance.
We collect personal and online identifiers for additional commercial and product purposes, including: sharing such information with our clients who typically use the information for their political campaign, PAC and association activities as well as marketing, advertising, authentication, identity resolution, fraud prevention, and/or fulfillment purposes.
Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information.
You may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.) However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
California residents may exercise their California privacy rights by submitting your deletion request to the online web form or request categories & personal data by submitting the online form, or by contacting us at 888-217-9600.
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of multiple identifiers (such as name, email address, voter ID) or to provide a piece of identification that confirms you are the person you claim to be.
Once we have verified your identity, we will respond to your request as appropriate:
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request so long as such information does not compromise the identity of individuals in our databases.
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”
Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section II of this Addendum.
If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information
We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf (for example providing us with a notarized written authorization or power of attorney).