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California Consumer Privacy Act (CCPA)

 

NOTICE TO CALIFORNIA CONSUMERS

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The following applies to you only if you are a California resident.


Your Rights and Choices


The California Privacy Rights Act (“CPRA”) provides consumers who are California residents with specific rights regarding their Personal Information.


Right to Access the Personal Information Collected, Disclosed, or Sold


As a California consumer, 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 as described below, we will disclose to you:

    •    The categories of Personal Information we collected about you
    •    The categories of the sources for the Personal Information we collected about you
    •    Our business or commercial purpose(s) for collecting, selling, or sharing that Personal Information
    •    The categories of third parties to whom we disclose, sell, or share that Personal Information
    •    The specific pieces of Personal information we collected about you

Right to Request Deletion of Personal Information

As a California consumer, you have the right to request that we delete any or all 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 notify our service providers or contractors to delete) your Personal Information from our records, and notify all third parties to whom we have sold or shared such Personal Information, to delete your Personal Information, unless this proves impossible or involves disproportionate effort.

We may deny your deletion request to delete your Personal Information if retaining the Personal Information is necessary for us, our service providers, or our contractors to:


    •    Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty, provide a good or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you
    •    Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes
    •    Debug 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 seq.)
    •    Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or  adheres to all other applicable ethics and privacy laws, when the information’s deletion is likely to render impossible or seriously impair such research, if you previously provided informed consent
    •    Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information
    •    Comply with a legal obligation

Right to Correct Inaccurate Information

As a California consumer, you have the right to request, if we maintain inaccurate Personal Information about you, to correct such inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

Right to Limit Use and Disclosure of Sensitive Personal Information

As a California consumer, you shall have the right, at any time, to direct that we limit our use of your sensitive Personal Information to that use which is necessary:


    •    To perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services
    •    To help ensure security and integrity to the extent the use of your sensitive Personal Information is reasonably necessary and proportionate for these purposes
    •    For short-term, transient use, including but not limited to, non-personalized advertising shown as part of your interaction with us, provided that your sensitive Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter an your experience outside the current interaction with us
    •    To perform services on behalf of us, or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of us
    •    To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

 

Right to Opt-Out of the Sale or Sharing of Personal Information


As a California consumer, you have the right, at any time, to direct that we not to sell or share (as those terms are defined in the CPRA) your Personal Information. If you would like to opt-out of the sale of your Personal Information, please click here. If you would like to opt-out of the sharing of your Personal Information, please click here.


Right to Non-Retaliation if You Exercise any of Your Rights


As a California consumer, you have the right not to be discriminated against for exercising any of your CPRA rights. Unless permitted by the CPRA, if you exercise any of your California rights, 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 CPRA that can result in different prices, rates, or quality levels. Any CPRA-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.
How to Exercise Your Rights to Know and to Delete
To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by either:


    •    Calling us at 888-428-3711
    •    Emailing us at info@ironsite.com
    •    Completing the form located here


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 request to know the Personal Information we disclose to service providers or third parties 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 your 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 if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. 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 will confirm receipt of your verifiable consumer request within ten (10) business days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), 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 immediately preceding our receipt of your verifiable 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 useable and should allow you to transmit the information from one entity to another entity.


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.
Information We Collect From California Consumers


We collect Personal 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 does not include:


    •    Publicly available information or lawfully obtained, truthful information that is a matter of public concern
    •    Deidentified or aggregated consumer information


Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other. The below also shows the categories of Personal Information that we have shared for a business and/or commercial purpose within the last twelve (12) months and the length of time we will retain this information. When we disclose Personal Information, 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.


Category of Personal InformationWhere we obtain Personal InformationBusiness purposes for which Personal Information is SharedCommercial purposes for which Personal Information is SharedService Providers or Third Parties with Whom Information is Shared Identifiers: A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone numberDirectly from you From third party data matching Automatically from pixels or cookies.

 

Performing services such as maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, or providing analytical services Providing advertising and marketing services, except for cross-context behavioral advertisingTo induce another person to buy goods or services To enable or effect, directly or indirectly, a commercial transactionAffiliates Advertising networks Internet service providers Data analytics providers Operating systems and platforms Social networks


Internet or similar network activity: Browsing history, search history, information regarding a consumer’s interaction with a website, mobile application, or online advertisementAutomatically from pixels or cookiesPerforming services such as maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, or providing analytical services Providing advertising and marketing services, except for cross-context behavioral advertisingTo induce another person to buy goods or services To enable or effect, directly or indirectly, a commercial transactionAffiliates Advertising networks Internet service providers Data analytics providers Operating systems and platforms Social networks Payment processors Email distribution services Website developers


Inferences drawn of other categories of Personal Information:   A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesAutomatically from pixels or cookiesPerforming services such as maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, or providing analytical services Providing advertising and marketing services, except for cross-context behavioral advertisingTo induce another person to buy goods or services To enable or effect, directly or indirectly, a commercial transactionAffiliates Advertising networks Internet service providers Data analytics providers Operating systems and platforms Social networks Payment processors Email distribution services Website developers


In addition to the above, we may use or disclose the Personal Information we collect for one or more of the following purposes:


    •    To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to fulfill your product order
    •    To provide you with information, products or services that you request from us
    •    To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you
    •    To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
    •    To improve our Website and present the contents to you
    •    For testing, research, analysis and product/service development
    •    As necessary or appropriate to protect the rights, property or safety of us, our users, or others
    •    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 CPRA
    •    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 is among the assets transferred

 

Sale of Personal Information


In the preceding twelve (12) months, we have not sold any Personal Information for monetary consideration. We do, however, disclose information for a commercial purpose by working with companies to deliver advertisements to you across the Internet. If you do not wish to have your Personal Information used for this purpose, please click the “Do Not Share My Information” link here, when you set up an account with us, or as shown on the first page of our websites.


We do not knowingly sell or share Personal Information of minors under 16 years of age without affirmative authorization.


Additional Information


Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following email address: info@ironsite.com and include the words “CALIFORNIA PRIVACY” in the subject line, and you must put the statement “Your California Privacy Rights” in the body of the request and state the name of our specific website with respect to which you are requesting the information as well as your name, street address, city, state, and zip code.


Please note the following:


    •    Users can visit the websites anonymously without providing their Personal Information, but we may collect Personal Information, such as IP addresses, automatically through the use of cookies or other tracking technologies; 
    •    We will add a link to this Privacy Policy on our home page, or at a minimum, on the first significant page after entering the website;
    •    Our Privacy Policy link includes the word “Privacy” and can be easily be found on the page specified above;
    •    Users will be notified of any privacy policy changes on our Privacy Policy page;
    •    Users are able to change their Personal Information by emailing us, by calling us, or updating their Personal Information in their online accounts with us;
    •    Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. We will recognize and process such signals in Users’ web browsers; and
    •    We allow the collection of users’ behavioral tracking by third parties for analytical and marketing purposes. 

Grievances and Complaints

Under California Civil Code Section 1789.3, residents of California who use this website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

ASSIGNMENT 


We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder to any successor.

CONTACT


If you have any questions about your privacy or security at the Website, or wish to update your Personal Information, please send an email to info@ironsite.com.

DATE LAST MODIFIED: June 1st, 2024

 


 

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