Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
- Publicly available or lawfully obtained, truthful information that is a matter of public concern.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA.
The chart below provides the categories of Personal Information and Sensitive Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold or “shared” (for cross-context behavioral advertising purposes) in the preceding twelve months since this notice was last updated. The examples of Personal Information and Sensitive Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information and Sensitive Personal Information associated with each category.
Category
| Collected | Disclosed | Sold/Shared |
A. Identifiers
Examples: Name, postal address, internet protocol address, email address, or other similar identifiers.
| Yes | Yes | Yes |
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Examples: Name, address, telephone number, education, employment, and employment history.
| Yes | Yes | Yes |
C. Characteristics of Protected Classifications under California or Federal Law
Examples: Age (over 40).
| No | N/A | N/A |
D. Commercial Information
Examples: Records of personal products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
| Yes | Yes | Yes |
E. Biometric Information
Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
| No | N/A | N/A |
F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
| Yes | Yes | Yes |
G. Geolocation Data
Example: Precise physical location.
| Yes | Yes | No |
H. Sensory Information
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
| No | N/A | N/A |
I. Professional or Employment-Related Information
Examples: Job application or resume information.
| Yes | Yes | No |
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
| No | N/A | N/A |
K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
| Yes | Yes | Yes |
L. Sensitive Personal Information (Identifiers)
Examples: A consumer’s social security, driver’s license, state identification card, or passport number.
| No | N/A | N/A |
M. Sensitive Personal Information (Log-In and Financial Information)
Examples: 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.
| No | N/A | N/A |
N. Sensitive Personal Information (Precise Geolocation)
Example: Geolocation data used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.
| Yes | Yes | No |
O. Sensitive Personal Information (Group Membership)
Examples: Racial or ethnic origin, religious or philosophical beliefs, or union membership.
| No | N/A | N/A |
P. Sensitive Personal Information (Contents of Communications)
Examples: The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
| No | N/A | N/A |
Q. Sensitive Personal Information (Genetic Data)
| No | N/A | N/A |
R. Sensitive Personal Information (Identifying Biometric Information)
| No | N/A | N/A |
S. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer’s Health)
| No | N/A | N/A |
T. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer’s Sex Life or Sexual Orientation)
| No | N/A | N/A |
|