Effective Date: 01/01/2021
Last Updated on: 01/01/2021
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information“) from some its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”) when you use our website, mobile or tablet application or other online services we provide (the “Platform”).
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|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).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||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, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Sources of Information We Collect
We may obtain your personal information from a variety of sources, including:
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
- We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
- We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential and prohibit using the disclosed information for any purpose except performing the contract. We may disclose your personal information as follows:
- To contractors, service providers and other third parties we use to support the Platform and our services and who are bound by contractual obligations to keep your personal information confidential.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred.
- To our affiliates and business partners.
- To third parties that provide advertising, content or functionality, or who analyze ad performance, on the Platform or other websites or platforms.
- To fulfill the purpose for which you provide it.
- To publish our own marketing and promotional materials.
- If required by applicable law.
- If we believe disclosure is necessary or appropriate to protect our rights, property or safety and that of our customers or others.
- To comply with a judicial proceeding, court order, other legal obligation or a regulatory or government inquiry.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- In the last 12 months, we have disclosed the following categories of personal information:
- We have disclosed this information to the following categories of third parties:
- You have the right to opt-out of sales of your personal information. We do not sell personal information, including your personal information or any personal information of children under the age of 16. In the preceding twelve (12) months, Company has not sold any personal information.
Your Rights and Choices
Shine the Light Protection
California Civil Code Section §1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if applicable. To make such a request, please contact us by visiting www.rekeepit.com/contact-us. If you believe any of the information we possess about you is incorrect, please contact us at the same webpage listed above.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you the following information for the last 12 months:
- 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.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
We are not required to provide you with these disclosures more than twice within a 12-month period.
If we deny your request for specific pieces of personal information, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA, we will inform you and explain the basis for the denial.
At no point will we ever disclose pursuant to a verifiable consumer request a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such information from you
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We use a two-step process for requests to delete personal information. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your personal information deleted. We will contact you further once your personal information has been deleted.
If we cannot verify the identity of the person requesting deletion of personal information, we may deny the request and will inform the requestor we cannot verify their identity. If we deny your request to delete personal information, we will notify you of the reasons why. We will delete any part of your personal information not covered by the exception allowing us to deny deletion of a portion of your personal information.
We do not provide these deletion rights for B2B personal information.
The CCPA provides consumers certain rights with respect to opting out of the sale of personal information. We do not sell your personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
- Emailing us at [email protected]
- Visiting www.rekeepit.com
A verifiable consumer request can only be made by you, by you on behalf of your minor child, or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf.
You may only submit a request to know twice within 12-month period. Your request to know or delete 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.
If you are using an authorized agent to exercise any of your rights under the CCPA, you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity.
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.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), 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 our receipt of your request. 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 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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time
Email: [email protected]
If you need to access this Policy in an alternative format due to having a disability, please contact [email protected].