California Privacy Notice

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Depending on your level of interaction with us, we may not have collected your personal information from all of the categories listed above.

We may use the categories of personal information listed above for the purposes described in our Online Privacy Notice. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80;

Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Notice. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have disclosed the information to, and (c) the categories of personal information we may have sold or shared.

a) Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

b) Disclosure of Personal Information

We may have disclosed your personal information to certain categories of third parties for the business purposes described in section 1 above, as listed in the table below.

c) Sale or Sharing of Personal Information

We have previously and will collect information about you for the purpose of providing it to our clients in situations described in our online privacy notice accessible here: https://emanate1dev.wpenginepowered.com/general-privacy-policy/. These situations include, for example, when we collect information about individuals for market research and focus groups; promotions; surveys and voting; media monitoring; and industry information. These services are provided at our clients’ request for monetary consideration. This may be considered the sale of personal information for purposes of the CCPA.

You have the right to opt out of this disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this California Notice, we may be considered to have sold or shared for the purposes of cross-context online behavioral advertising, the following categories of personal information for the purposes described above: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.

California Consumer Privacy Rights

We do not sell or share the personal information of minors under 16 years of age without affirmative authorization from either a minor who is less than 16 (but greater than 13) years of age, or the parent or guardian of a consumer less than 13 years of age if we have actual knowledge of the individual’s age. To our knowledge, we do not sell or share the personal information of minors under 16 years of age.

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal information. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

• The categories of personal information we collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting, selling, or sharing that personal information.
• The categories of third parties with whom we disclose personal information.
• The specific pieces of personal information we collected about you.

Deletion: You have the right to request that we delete certain personal information we have collected from you, 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. However, we may retain personal information that has been de-identified or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under the CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

Portability: You have the right to request a copy of personal information we have collected and maintained about you. The CCPA allows you to request your information from us up to twice during a 12-month period. We will provide our response in a readily usable (and usually electronic) format.

Correction: You have the right to request the correction of any personal information we maintain about you.

Opt-Out of Sales or Sharing: You have the right to opt-out of the sale or sharing of your personal information. To exercise the right to opt out, you (or your authorized representative) may submit an opt-out request by following the instruction below. We will also treat Global Privacy Control browser signals as valid opt-out requests.

You may change your mind and opt back in to personal information sales at any time by emailing us at [email protected].

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.

How to Exercise Your Privacy Rights: To exercise your rights described above or to submit a Shine the Light request, please email us at [email protected].

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above). We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This California Notice is available in alternative formats upon request. Please contact [email protected] to request this California Notice in an alternative format.