b. Use of personal information
In the last 12 months, we have used your personal information for the business and commercial purposes described below.
a. Category A: Identifiers
b. Category B: Personal Information categories listed in the California Customer Records statute
c. Category D: Commercial Information
d. Category F: Internet or other similar network activity
e. Category G: Geolocation data
f. Category K: Inferences drawn from other Personal Information
We may also use your personal information to carry out our obligations and enforce our rights, comply with our legal obligations under the laws or regulations, and respond to regulatory inquiries, subpoenas, or court orders.
c. Selling your personal information
Selling your personal information means us selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or electronically, your personal information to a third party for monetary or other valuable consideration.
We have not sold your personal information in the last 12 months.
In the last 12 months, we have used your personal information for the business and commercial purposes described below.
We may also use your personal information to carry out our obligations and enforce our rights, comply with our legal obligations under the laws or regulations, and respond to regulatory inquiries, subpoenas, or court orders.
Selling your personal information means us selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or electronically, your personal information to a third party for monetary or other valuable consideration.
We have not sold your personal information in the last 12 months.
d. Disclosing your personal information
• Business purpose: In the last 12 months, we have disclosed the following categories of personal information with our service providers for our business purposes:
o Category A: Identifiers
o Category B: Personal Information categories listed in the California Customer Records statute
o Category D: Commercial Information
o Category F: Internet or other similar network activity
o Category G: Geolocation data
o Category K: Inferences drawn from other Personal Information
The business purposes for sharing such information with service providers include performing transactions, managing our relationship with you, and monitoring for security threats and fraud. We provide the above categories of personal information for business purposes to the following service providers: payment processors/service providers, professional service providers such as auditors and lawyers, and consultants.
The business purposes for sharing such information with service providers include performing transactions, managing our relationship with you, and monitoring for security threats and fraud.
We provide the above categories of personal information for business purposes to the following service providers: payment processors/service providers, professional service providers such as auditors and lawyers, and consultants.
• Other commercial purpose: In the last 12 months, we have shared the following categories of your personal information with third parties in a manner that is likely to be considered to be a “sharing” for cross context behavioral advertising under the CCPA:
o Category F: Internet or other similar network activity
o Category K: Inferences drawn from other Personal Information
Both categories were shared for commercial purposes with third parties for personalization, analytics, marketing and promotion of our products and services. To opt-out from Amoon sharing your personal information, please see Section j for your right to opt-out of Sharing your information. We provide the above categories of personal information for commercial purposes to the following service providers: analytics services, and online marketing services.
e. Using your sensitive personal information
Sensitive personal information means personal information that reveals (A) a consumer’s social security number, driver’s license, state identification card, or passport number; (B) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) consumer’s genetic data; (G) biometric information for the purpose of uniquely identifying a consumer; (H) personal information collected and analyzed concerning a consumer’s health; or (I) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
In the last 12 months, we may have collected and used the following sensitive personal information.
o A consumer’s financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
This information is used to process your payment for the Services and deliver the Services to you. Because this is the only use of sensitive personal information and our use is reasonably necessary and proportionate to the purpose, we are not required to post a notice of right to the limit use of sensitive personal information.
f. Retention criteria of your personal information
We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retrain your personal information to comply with our legal or reporting obligations in accordance with the law or to defend against claims or for internal analysis purposes (such analysis purposes are generally subject to shorter retention periods, whenever possible). Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:
• The volume, nature, and sensitivity of your information;
• The potential risk of unauthorized access, use or disclosure, or misappropriation;
• The purposes for which we process your personal information; and
• The retention obligations under applicable legal requirements.
g. Your right to know
You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we verify your 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.
• If we sold or shared your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that the recipient purchased; and disclosures for a business purpose, identifying the personal information categories that recipient obtained.
h. Your right to obtain a copy of your personal information
You have a right to obtain a copy of the specific pieces of personal information we collected about you (also called a data portability request). Once we verify your request, we will provide you with a copy of your personal information that is responsive to your request.
i. Your right to delete your personal information
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 verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
j. Your right to opt-out of Sharing your information
We do not sell or share personal information with third parties that would be considered a “sale” under the CCPA. We do share your personal information for targeted advertising. To exercise your right to opt-out from us sharing your personal information, you or your authorized representative may submit a request at Your Privacy Choices.
k. Opt-out preference signals
Opt-out preference signals or Global Privacy Controls (GPC) provide consumers with a simple and easy-to-use method by which consumers interacting with us online can automatically exercise their opt-out of sale/sharing rights. We will process any opt-out preference signals that meet the following requirements:
(1) A signal that is in a format commonly used and recognized by businesses; and
(2) The technology or mechanism that sends the opt-out preference signal makes clear to the consumer that the use of the signal is meant to have the effect of opting the consumer out of sale and sharing of their personal information. For example, such technology or mechanism may be an HTTP header field, JavaScript Object, or most commonly, a browser tool or extension that allows users to send the opt-out signal.
l. How to exercise your CCPA rights
To exercise your right to know, right to obtain a copy, or right to delete your personal information as described above, please submit your request to us by contacting us at 1-844-234-3171 or submit your request at Your Privacy Choices.
m. How we verify requests and respond to requests
Before fulfilling your request, we take steps to verify that you are who you say you are or you have the authority to act on someone else’s behalf. Therefore, upon receipt of your request, we may request additional information that we need to verify you and, if you are submitting a request on behalf of someone else, to verify that you are permitted to act on that person’s behalf.
When we contact you to request verification information, please respond and provide the information that we have requested. Depending on the nature of your request, we will verify your identity to either a reasonable or high degree of certainty. This may mean that we need to match two or three pieces of information that we hold about you with information that you provide to us.
In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request. We cannot respond to your request or provide you with personal information if we cannot confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request and to locate relevant information. 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 to understand, evaluate, and respond to your request.
We cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
n. Who may submit requests?
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.
o. How often can you submit requests?
You may make a CCPA consumer request twice within a 12-month period.
p. Response timing and format
We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require an additional forty-five (45) days to respond to your request. We will inform you of the reason and extension period in writing.
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 the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. When you request a copy of your personal information, 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 easily.
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 a cost estimate before completing your request.
q. Non-discrimination
We will not discriminate against you for exercising any of your CCPA rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.
r. Notice of financial incentives
We do not offer financial incentives or pricing discounts for providing your personal information.
