Effective Date: January 1, 2020
Information We Collect
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 or household (“personal information”). Personal information does not include publicly available information, deidentified information, aggregate information, or any information protected by other privacy laws and otherwise excluded from the scope of the CCPA.
This table identifies the categories of personal information we have collected directly or indirectly from our consumers within the last 12 months:
|A. Identifiers||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 listed in the California Customer Records statute||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||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||No|
|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||No|
|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||No|
|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 (as defined by the Family Educational rights and Privacy Act)||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||No|
How We Use Your Information
We may use or disclose the personal information we collect for one or more of the following business or commercial purposes:
- To fulfill the reason you provided the information (e.g., to make your hotel reservation);
- To provide you with the products and services you request;
- To operate, support, personalize, and develop our website;
- To create, maintain, customize, and secure your account with us
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website and via email or text message (with your consent, where required by law);
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets;
- For testing, research, analysis, and product development, including to develop and improve our website, products, and services;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your personal information or as otherwise set forth in the CCPA; or
- To evaluate or conduct 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 our customers is among the assets transferred.
Sharing Personal Information
We may disclose your personal information for a business purpose to our service providers and third parties such as our subsidiaries and affiliates, as well as non-affiliated third parties with whom we partner to offer products and services to you.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the third parties identified above:
Category A. Identifiers
Category B. Personal information listed in the California Customer Records statute
Category C. Protected classification characteristics under California or federal law
Category F. Internet or other similar network activity
[In the preceding 12 months, we have not sold any personal information.]
Your CCPA Privacy Rights and Choices
If you are a California resident, the CCPA provides you with additional rights regarding our use of your personal information. This section describes your CCPA rights and explains how to exercise those rights.
(1) Right to Access Your Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information during the 12 month period preceding your request. Once we receive and verify your request, we will disclose to you the information that you request and we are obligated to provide under the CCPA, which may include:
- The categories of personal information we have collected about you;
- The categories of sources from which we collected your personal information;
- Our business or commercial purpose for collecting your personal information;
- The categories of your personal information we have disclosed for a business purpose;
- The categories of third parties with whom we share your personal information; and
- The specific pieces of personal information we have collected about you.
(2) Right to Request Deletion
You have the right to request that we delete some or all of the personal information that we have collected from you, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to whom we have furnished that information to also delete) your personal information from our (and their) records. With respect to the exceptions, we may deny your deletion request in whole or in part if retaining your personal 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;
- 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 your expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
(3) Right to Opt-Out
[You have the right to direct a business not to sell your personal information at any time. Because it is our policy not to sell your personal information, we are exempt from providing any mechanism for you to exercise this right.]
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you services, charge you different prices for any services, provide you with a different level or quality of services, or suggest that you may receive a different price or rate for services or a different level or quality of services.
Exercising Your Rights
You may request that we disclose or delete your personal information, as described above, by submitting a verifiable consumer request to 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 information. You may only make a verifiable consumer request for access twice within any 12-month period. Your verifiable consumer request must (1) describe your request with sufficient detail so that we may understand, evaluate, and respond to it, and (2) include your name and any email address or phone number you have provided to us, so that we may 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 then confirm the personal information requested relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Additional California Privacy Rights
Under California’s “Shine the Light” law, you may also have the right to request and receive information about disclosure of your personally identifiable information to third parties for their direct marketing purposes. Because it is our policy not to share personally identifiable information with third parties for third-party direct marketing purposes without consent, we are exempt from the requirement to respond to such requests.
If you have any questions about this California Privacy Notice, please contact us at firstname.lastname@example.org.