Effective Date: December 1, 2019
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 users within the last twelve (12) months:
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||YES|
|C. Protected classification characteristics under California or federal law.||NO|
|D. Commercial information.||NO|
|E. Biometric information.||NO|
|F. Internet or other similar network activity.||YES|
|G. Geolocation data.||NO|
|H. Sensory data.||NO|
|I. Professional or employment-related information.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||NO|
|K. Inferences drawn from other personal information.||NO|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
Information excluded from the CCPA's and the Nevada Act'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.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete when you register on our website.
- Indirectly from you. For example, from observing your actions on our website and the links that you click on emails that we send you.
- From third-party business partners including partners with websites on which we have placed web beacons, which allow us to determine that you have visited a particular website or have clicked on a particular link[, and from other partners such as [eg, social media sites, ad networks, and analytics providers].
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 provide your personal information to utilize our services, we will use that information to deliver the service and refine our processes to more effectively provide services to you in the future.
- To recognize you when you return to our website.
- To process your requests, and to speed up your searches.
- To store information about your preferences, allowing us to customize our website according to your individual interests.
- To provide, develop, and support our website and our services.
- To create, maintain, customize, and secure your account with us.
- To personalize your experience on our website and to deliver content and product and service offerings relevant to your interests.
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our website and our services.
- To estimate our audience size and usage patterns.
- 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 and/or the Nevada Act.
- In the event that we need 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 about our website users is among the assets transferred.
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.
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:
- Service providers (advertisers, ad networks and servers, content providers and application providers).
- Data aggregators (collecting data from both online and offline sources).
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Data aggregators
Sales of Personal Information
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information, and the Nevada Act provides Nevada consumers with specific rights regarding their personal information. If you fall within either of these groups, this section describes your rights and explains how to exercise those rights.
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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- 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:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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 (see Exercising Access, Data Portability, and Deletion Rights), 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 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:
- Emailing us at firstname.lastname@example.org or.
- Sending a letter to us at Austinshire Partners,Unit 10031, PO Box 6945, London, W1A 6US, United Kingdom
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. Although we never intentionally collect information regarding minors, 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.
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.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
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 an additional 90 days if you are a California resident, or an additional 45 days if you are a Nevada consumer), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "Right to Opt-Out"). We never intentionally collect information from users that we actually know are less than 16 years of age, and will never sell the personal information of users we actually know are less than 16 years of age. Users who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us: email@example.com.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us at the email address or phone number provided in this notice.
You do not need to create an account with us to exercise your Right to Opt-Out. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your rights. Unless permitted by the CCPA or the Nevada Act, as applicable, 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, if you are a California resident, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-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.
Other California Privacy Rights
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. Nevada consumers have the same right under the Nevada Act. To make such a request, please send an email to firstname.lastname@example.org.
Changes to Our Privacy Notice
We reserve the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the website and update the Notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which we collect and use your information described above, your choices
and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
email@example.com, or here
or send us correspondence at the following address: