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California Consumer Privacy Statement

This California Consumer Privacy Statement supplements Electra Information Systems’ Privacy Policy and applies solely to California consumers.  This section provides information about our online and offline privacy practices.  This Statement does not apply to our personnel.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

 

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

 

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers


Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information


Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status


Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies


Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements


Geolocation Data


Sensory Information: audio, electronic, visual, and similar information


Employment Information: professional or employment-related information


Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)


Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


We may use the categories of personal information listed above for the purposes described in our Privacy Policy.  In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table: 

 

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Debugging to identify and repair errors that impair existing intended functionality

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Undertaking internal research for technological development and demonstration

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

 

In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

 

a.  Sources of Personal Information

 

We may have obtained personal information about you from various sources, as described below.

 

Categories of Sources of Data Collection

Categories of Personal Information

Directly from you, such as when you contact us with a question or comment

 

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

From your devices, such as when you visit our Site

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Your family or friends, such as when they provide us with your contact information so we can send information that may interest you

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Our affiliates and subsidiaries

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Vendors who provide services on our behalf

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Social networks

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Online advertising companies

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Government entities

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Consumer data resellers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

 

b.  Sharing of Personal Information

 

We may have shared your personal information with certain categories of third parties, as described below.

 

Categories of Third Parties

Categories of Personal Information

Our affiliates and subsidiaries

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Vendors who provide services on our behalf

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Professional services organizations, such as auditors and law firms

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Our joint marketing partners

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Our business partners

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Advertising networks

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Internet service providers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Data analytics providers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Government entities

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Operating systems and platforms

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Social networks

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

Consumer data resellers

Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information;  Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences

 

c.  Sale of Personal Information

 

We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you).  You have the right to opt out of this disclosure of your information, as detailed below. 

 

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

 

d.  Disclosure of Personal Information for a Business Purpose

 

We may have disclosed to third parties the following categories of personal information for a business purpose:

 

- Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

 

- Signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information

 

- Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status

 

- Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

 

- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

 

- Geolocation Data

 

- Audio, electronic, visual, and similar information

 

- Professional or employment-related information

 

- Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

 

- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

 

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. 

 

Deletion: You have the right to request that we delete certain personal information we have collected from you.

 

How to Submit a Request: To submit an access or deletion request, please contact us by:

 

- sending an e-mail here; or
- writing to us at:

 

Attention: Privacy Policy Officer
Electra Information Systems, Inc.
381 Park Avenue South, Room 1413
New York, New York, 10016

 

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request If you request access to or deletion of your personal information, we may require you to provide reasonable identification information. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.  If you designate an authorized agent to make an access or deletion request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

 

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact us to request this Statement in an alternative format by:

 

- sending an e-mail here; or

- writing to us at:

 

Attention: Privacy Policy Officer
Electra Information Systems, Inc.
381 Park Avenue South, Room 1413
New York, New York, 10016

California Consumer Privacy Statement Effective Date: December 29, 2019

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