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CCPA Privacy Notice

PRIVACY STATEMENT-CALIFORNIA

 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in IdentityMind Global Inc.’s (collectively “we”, “us”, or “our”) Privacy Shield Policy, GDPR Statement, Privacy Policy  and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). This notice is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”) which is effective as of January 1, 2020 and other California Privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice. This Notice does not cover personal information not subject to the CCPA rights.

 

Information We Collect:

We collect several types of information from and about users of our Website and/or Services, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline (“personal information”); and/or
  • That is about you but is anonymized so that the collected information does not identify you. 

 

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site or use any of our Products. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.
  • From third parties, for example, our customer.

 

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including 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.

 

Use of Personal Information

We use information that we collect about you or that you provide to us or our customers, including any personal information in the following manner:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients 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 CCPA.

We will not collect additional personal information data or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.  We also do not sell personal information, so we don’t have an opt-out feature.

 

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.

 

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 for by 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.

 

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

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 (16 years old or younger).

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  Any additional requests during the same 12-month period will be processed by us after payment of an administrative fee.  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.  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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 or 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 preceding the verifiable consumer request’s receipt. If applicable, the response we provide will also explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your personal information that is readily useable 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.

 

Non-Discrimination

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 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.

 

 

Changes to Our Privacy Policy

We reserve the right to amend or update this CCPA Privacy Notice at any time. We may or may not notify you of such changes, however, you can always view the most current version of this privacy policy at any time at: www.identitymindglobal.com/ccpa-privacy-notice.  The date of the last revision appears at the end of this policy.  Once the revision is effective, your use of our services and your data will be governed by the most recently revised CCPA Privacy Notice.  If you do not want to be bound by the changes to the Privacy Notice, you may revoke your consent by contacting us as described above and ask that we delete your data from our database.

 

 

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows

Phone:  1 (213) 867-2611

Website:  www.identitymind.com

Email: [email protected]

Mail:  Identity Mind, Inc.

Attn:  Data Privacy Officer

          645 High Street

          Palo Alto, CA   94303

 

Last Revised:  December 31, 2019