PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
Effective date: September 2020
This Privacy Notice for California residents went into effect in 2020 and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you").
1. CATEGORIES OF INFORMATION WE COLLECT
Our Website collects information that identifies, relates to, describes,references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:
(1). Identifiers, such as: names, e-mail addresses, Internet Protocol addresses, or other similar identifiers.
(2). Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as: 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. Collected: Yes.
(3). Protected classification characteristics under California or federal law such as: Age, 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). Collected: Yes.
(4). Commercial information obtained, purchased or considered, such as records of personal property, records of products or services purchased or other purchasing or use histories or tendencies. Collected: No.
(5). Biometric information
(6). Activity information relating to internet or other electronic networks such as browsing or searching history, or interaction with a website, ador app. Collected: No.
(7). Geolocation information
(8). Audio, visual, thermal, electronic, olfactory or other similar information
(9). Information related to employment or other professional standings
(10). Information related to education
(11). Any inferences drawn using any of the above information in order to profile a consumer and reflect the consumer’s preferences, characteristics, psychological trends, predispositions, behavior,attitudes, intelligence, abilities and aptitudes.
- Publicly available information from government records
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope and covered by certain sector-specific privacy laws, including but not limited to Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
3. PERSONAL INFORMATION SOURCES
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete on our website.
- Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
4. Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our programs or services, we will use that personal information to respond to your inquiry. If you provide your personal information to make a donation or purchase a ticket to a class, we will use that information to process your payment and facilitate delivery.
- 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 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.
- 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.
5. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
- We share your personal information with the following categories of third parties: consultants (instructors, educational venders, back-end vendors to process payments, etc.)
- Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, we have not explicitly disclosed personal information for a business purpose to anyone other than partnering entities (see prior question).
- Sales of Personal Information in the preceding twelve (12) months -we have not sold personal information in the preceding twelve (12)months or ever.
6. Your Rights and Choices.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. This is comprehensive but not limited to this (see initial “terms & policies” page for updated CCPA information).
(1) Access to Specific Information and Data Portability Rights. 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. Once we receive and confirm your verifiable consumer request, we will disclose that information to you:
We share your personal information with the following categories of third parties: Payment processors or the purposes of facilitating a payment and partnering consultants/vendors to provide programming
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.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
(2) Deletion Request Rights. 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 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.
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, 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 forby 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.
(3) Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, you need to submit a verifiable consumer request to us by sending us an email or written notice via mail to firstname.lastname@example.org. 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 personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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.
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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, 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. For data portability requests, we will select a format to provide your personal information that is readily use able and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
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.
7. Personal Information Sales Opt-Out and Opt-In Rights.
We do not sell personal information of consumers.
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 programs 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.
California’s "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Although we make no such disclosures, you may make such a request. Please email us at: email@example.com to do so.