California Consumer Privacy Act Disclosures
- enable your participation in activities on our Platforms;
- provide our offerings and services to you;
- confirm your identity;
- enforce our Platform policies and terms of service, and investigate potential violations of such policies or terms;
- fulfill an order that you place through any of our Platforms, including to process payment for any purchase made through any of our Platforms;
- respond to inquiries that you may have about any of our Platforms or services;
- administer your account on any of our Platforms;
- display our content based upon your interests;
- enable you to search information on our Platforms;
- list in our search and directory services any users who provide services through one of our Platforms;
- contact you regarding customer service and customer surveys;
- assess your needs and interests in our products and services in order to better tailor our offers and/or advertising;
- improve our Platforms;
- inform you of changes made to our Platforms;
- organize or carry out promotional activities, games or promotional events;
- inform you of products, services, promotions, offers, and competitions which you may find interesting, provided you have not opted out of receiving such information or, where required, we have your express consent;
- conduct research;
- understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services; and
- conduct other marketing and commercial activities.
A. Categories of personal information as referenced in Cal. Civ. Code 1798.130 (c) |
B. Categories of personal information that we collected about the consumer (by reference to the enumerated category or categories in column A that most closely describes the personal information collected) |
C. Was the personal information described in in column B disclosed for a business purpose? |
D.Retention |
E. We disclosed personal information in one or more categories listed in column B to the following categories of third parties: |
Identifiers such as a 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. | Name, username, email address, current and previous mailing addresses, social security number or tax identification number, driver's license number or other government issued identification number (or a copy of driver's license or other government issued identification card), unique device ID, machine ID, Internet protocol address | Yes | As long as necessary to provide the service and comply with legal obligations |
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Any categories of personal information described in subdivision (e) of Section 1798.80: "Personal information" means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, social security number, address, telephone number, passport number, driver's license or state identification card number, bank account number, credit card number, debit card number, or any other financial information. "Personal information" does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. | Telephone number, mobile phone number, payment address, credit or debit card or PayPal account information, other financial account number, information about you in correspondence, mail, and chats conducted through a Platform, information you post or otherwise share on any SNS to which you have connected your Platform profile, content you post in online reviews, comments, forums, or blogs on our Platforms, date of birth, time of birth, birth location, login, PIN, password, account preferences, time zone, any telephone number from which you contact us or from which you place a call to another user through our calling feature on any of our Platforms, device type, computer and connection information, browser type, domain name, and date and time stamps for your visits. | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
Characteristics of protected classifications under California or federal law, including 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). | It is possible that users of our site relay such information to each other in which case it would be temporarily stored in chat or email transcripts that we store for security, administrative, and legal purposes (including to detect, prevent, or otherwise address fraud, security or technical issues). | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Responses to our customer satisfaction surveys or customer service communications. | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement. | Cookies, pixel tags, web beacons, information such as the URL that you visited before you come to the Platform and the URL to which you next go, information about the way you interact with any of our Platforms or any content thereon, statistics regarding your page views and traffic to and from our Platforms, and the number of bytes transferred, hyperlinks clicked, and other actions you take on our Platforms. | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
Geolocation data. | Geolocation information | Yes | Same as above. | |
Audio, electronic, or similar information. | Live telephone conversations with other users through the Platform. | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
Sensitive Personal Information |
Geolocation information. | Yes | As long as necessary to provide the service and comply with legal obligations | Same as above. |
3. Disclosures of Personal Information; No Sales
Over the preceding 12 months, we disclosed certain categories of California residents' personal information to the categories of third parties as shown in the table above. The brands associated with the marketplace side of our business (i.e., Keen.com and LiveAdvice.com) do not sell, and in the preceding 12 months did not sell, California residents' personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to privacy@ingenio.com or mail a written request to our address at the end of this document and include "California Request to Delete" in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA. We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
5. Right to Request Correction
You have a right to request the correction of personal information that we collect or maintain about you. To submit a request to correct personal information, please submit an email request to privacy@ingenio.com or mail a written request to our address at the end of this document and include "California Request to Correct" in the subject line. Please specify in your request the personal information about you that you would like to have corrected. We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
6. Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code § 1798.125.6. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 2 and 3 above:
- Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to 182 Howard Street, #826, San Francisco, CA 94105; and
- Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
7. Contact for More Information
If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details:
- Email address: privacy@ingenio.com
- Postal address: 182 Howard Street, #826, San Francisco, CA 94105
Last Updated: December 12, 2022
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