Last updated: December 20, 2021
California Privacy Notice
The following California Privacy Notice ('California Notice') supplements the disclosures contained in our Privacy Notice and applies solely to individual residents of the State of California ('consumers' or 'you').
This California Notice: (A) provides additional details about how we collect, process, and disclose your Personal Information, (B) summarizes your rights under the California Consumer Privacy Act ('CCPA') and certain other California privacy laws, and (C) provides details about how you can exercise these rights. Unless otherwise expressly stated, all terms in the California Notice have the same meaning as defined in our Privacy Notice or as defined in the CCPA.
'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. Personal Information does not include information that is not subject to the CCPA, including de-identified data or aggregate consumer information.
1. Categories of Information We Collect
This Section 1 describes our practices currently and during the preceding 12 months. We collect the following categories of Personal Information:
|Category (information collected may correspond to more than one category)||Example||Source||Third-party Recipients|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifier|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A real name, address, phone number, or payment account number|
|Protected classification characteristics under California or federal law||Age, race, marital status, gender identity, or gender expression|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Internet or similar network activity||Browsing history, search history, information on your interaction with our Platform or advertisements|
|Geolocation data||Precise geolocation of your device when you grant us access to it|
|Audio data||Recorded calls with our customer support team|
|Inferences drawn from other Personal Information||Information generated from your use of the Platform reflecting your preferences|
The business and commercial purposes for which we use such Personal Information are described in our Privacy Notice.
2. Sharing, Disclosing, and Selling Personal Information
We share Personal Information with third parties for business purposes and may also 'sell' your Personal Information to third parties, as that term is defined under the CCPA. Any sales of data are subject to your right to opt-out, as described below. This Section 2 describes our practices currently and during the preceding 12 months.
The chart in Section 1 identifies the categories of third parties with which we share Personal Information for businesses purposes. We may also disclose Personal Information to third parties: (1) at your direction or upon your request, (2) as required to provide you with services that you request, (3) in connection with a corporate business transaction, or (4) to comply with legal or contractual obligations or in connection with the protection of our rights. See our Privacy Notice for more detail on the sharing and disclosures described above.
Like many online services, we work with third party ad networks, advertising companies, social media sites, consultants, and brand partners. We may provide these third parties with Personal Information directly or enable them to collect Personal Information from your browser or device through cookies and similar technologies when you interact with our Platform. Please review the information on our Interest Based Ads page for more details. These activities may constitute a 'sale' of Personal Information to those third parties for purposes of the CCPA of the following categories of information:
- California Customer Records Information
- Commercial Information
- Internet or similar network activity
3. California Privacy Rights
As a California resident, you may be able to exercise the following rights (collectively, the 'California Privacy Rights') in relation to the Personal Information about you that we have collected (subject to certain legal limitations):Right to Opt-Out
You have the right to opt-out of any 'sale' of your Personal Information as defined by the CCPA. You do not need to create an account with us to exercise your Right to Opt-out. However, we may ask you to provide additional Personal Information so that we can identify you and process your opt-out request. We will only use Personal Information that you provide in an opt-out request to review and comply with your request.
To exercise your right to opt-out, you (or your authorized representative) may submit a request to us by submitting a request using our Do Not Sell Form. Please note that the third parties to whom we sell Personal Information may use such information for their own purposes in accordance with their own privacy notices.Right Access to Specific Information; Data Portability Rights.
You have the right to request that we disclose the following information to you about our collection and use of your Personal Information over the past 12 months: (1) the categories of Personal Information we collected about you, (2) the categories of sources of the Personal Information we collected about you, (3) our business or commercial purpose for collecting or selling that Personal Information, (4) the categories of third parties with whom we have shares that Personal Information, and (5) the specific pieces of Personal Information that we collected about you (also called a data portability request).
To exercise these rights, you (or your authorized representative) may submit a request to us by submitting a request using our Data Rights Request Form.Right to Delete Your Information
You have the right to request that we delete any of the Personal Information that we collected from you and retained.
Your right to delete is subject to certain exceptions under the CCPA, including but not limited to exceptions for information 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 for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 etc.).
- 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.
- 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.
- To exercise your right to delete your data, you (or your authorized representative) may submit a request to us by submitting a request using our Data Rights Request Form.
We will need to verify your identity before processing any access or deletion requests, which may require us to request additional Personal Information from you or require you to log into your account. We will only use Personal Information that you provide in connection with a California Privacy Rights request to review and comply with your request. You may also designate an authorized agent to make requests on your behalf. In order to be able to act, authorized agents must submit a request to [email protected] and provide sufficient evidence to demonstrate that the requestor is an authorized agent with written permission to act on your behalf.Requests from Authorized Agents
You may submit privacy-related requests through an agent authorized to act on your behalf. The agent must prove their identity and establish that they are authorized to act on your behalf by sending: (1) a notarized Power of Attorney or Affidavit; and (2) details about your request to [email protected]. We may be required to take additional steps to verify your identity or your relationship with the agent before processing the request.
You are entitled to exercise your CCPA rights free from discrimination, as required by the CCPA.
5. 'Shine the Light' Disclosure
California’s 'Shine the Light' law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us for personal, family or household purposes with regard to the disclosure of certain types of Personal Information to third parties for their direct marketing purposes. To opt-out of having your Personal Information disclosed to third parties for their direct marketing purposes, please click the Do Not Sell My Personal Information link in the footer of this webpage or fill out Data Rights Request Form.
6. Updates to This California Notice
If we make material changes to this California Notice, we will change the date at the top of this Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification. If you do not cancel your Account before the date the revised California Notice becomes effective, you will be subject to the revised California Notice.
7. Contact Us
If you have any questions or requests in connection with this California Notice or other privacy-related matters, please send an email to [email protected]
Alternatively, inquiries may be addressed to:
Attn: Privacy Officer
177 Huntington Ave, Ste 1703
Boston, MA 02115-3153