Privacy Satement California
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policies that apply to your use of the websites made available by Mobile Posse, Inc. (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
This privacy statement only applies to our website practices (the “Services”). We are not responsible for the actions and privacy policies of third party websites, partners, or their services.
Please Note: Our websites do not “sell” any information of users. We may collect information such as a name and email address for anyone who contacts us for customer support questions.
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Information We Collect
We collect and use the following categories of information. We also state whether this information is shared or “sold” to third parties.
- Categories of Personal Information Collected or Used by the Services: Identifying information about you. We may collect your name and email address if you submit it to us for a specific customer support questions and we use this information solely to respond to you. This information is not “sold” or shared with any third party.
- Categories of Personal Information Collected or Used by the Applications: Internet or other electronic network activity information
Examples: We collect information on how a user interacts with our Services, including user page views, device platform, date and time when a user interacts with our web sites, the type of content delivered to the user (e.g., entertainment news), and the number of clicks per session.
Primary Purpose of Collection: This information helps us assess what features and content are of interest to its users and to measure the web sites efficiency in delivering its services.
Do we share or sell this data? We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We do not sell this data or share it for marketing purposes.
Categories of Information that We Do Not Collect
We do not collect or share the following categories of personal information:
- Identifiers such as name, postal address, email address, account name, social security number, driver’s license number, passport number, employment history, or financial information.
- Characteristics of protected classifications under California or federal law.
- Commercial information.
- Biometric information.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information.
- Inferences drawn from information to create a profile.
We will retain as permitted under the CCPA certain data analyzed and processed by us, such as when a user has accepted our terms for the Application and such other data reasonably anticipated within the context of our relationship with you or solely for internal business purposes.
How we Use Your Information
In addition to the primary purposes of collection noted above, we may generally use the categories of information noted above as follows:
- Provide you with access to the Services.
- Customize your experience with the Services.
- Contact you through the service to provide you with important information, notices, and promotions.
- Protect our rights and property and those of our other customers against unauthorized use.
- Aggregate information for business purposes that include market analysis or traffic flow.
Sharing Personal Information
We may share your Information from our Services with data hosting services and analytical services to provide us with business, professional or technical support.
We share your personal information with the following categories of third parties: Service Providers, which include data hosting services and analytics services that process information on our behalf under a written contract.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know: 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, we will disclose to you:
- The categories of personal information that we have collected.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom the business shares personal information.
- The categories of personal information that the business sold about the consumer and
- the categories of third parties to whom the personal information was sold, by category or
- categories of personal information for each third party to whom the personal information
- was sold.
You can submit your request by:
- Email firstname.lastname@example.org
- Call 1-866-304-3097.
Right To Delete Data
You have the right to request that we delete any of your Information collected and retained by us 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 providers 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.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
Exercising Deletion Rights
You have a right to ask us to delete your data. You can submit your request by:
- Email at email@example.com
- Calling us at 1-866-304-3097
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.
Right to Designate an Authorized Agent
Users of the Services can designate an authorized agent to make a request under the CCPA if they provide that agent with their User ID information. Please note that this action would allow such agent access to all information contained in the Application. If a user chooses to take this action, they do so entirely at their own risk and we disclaim all responsibility and liability for how such agent may access, use or disclose the information they obtain.
The agent will need to have your User ID to make a request. We are not able to identify a user based on name or email address since we do not collect this information. Agents must submit requests to firstname.lastname@example.org. Users can provide their User ID information using the process described below.
Limitations on the Number of Requests
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. If we are unable to link your request with your User ID, we will provide you instructions on how you can locate your User ID on your device. 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. We will retain this information in accordance with the CCPA.
Response Timing and Format
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 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.
Children Under the Age of 16
Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information on our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Services. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
We provide our services at no cost to you. Unless permitted by the CCPA, we will not discriminate against you for exercising any of your CCPA rights.
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 notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address: Mobile Posse, Inc.
1010 N. Glebe Road, Suite 800
Arlington, VA 22201
Updated: 3 January 2020