This California Consumer Privacy Act (“CCPA”) policy (this “CCPA Policy”) supplements our Privacy Policy and applies to solely to residents of the State of California (“Consumers” or “You”) and to 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”). We provide this CCPA Policy to the extent we act as, and to comply with our obligations as, a “Business” under CCPA.

As used in this CCPA Policy, the term “Personal Information” does not include categories of information excluded from the CCPA, such as personal information reflecting a written or verbal communication or a transaction between us and a Consumer who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with us occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit, or government agency.

Additionally, this CCPA Policy does not apply to information we collect, maintain, or disclose in our capacity as a “Service Provider” under CCPA on behalf of our clients and their authorized partners. If your information has been submitted to us as part of our performance of those services and you would like to learn more about the handling of that information or exercise any rights you may have under the CCPA, please inquire with the client or authorized partner directly.

Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Policy or, if not defined herein or in the Privacy Policy, the CCPA. To the extent of any conflict between this CCPA Policy and our Privacy Policy, this CCPA Policy shall control with respect to Consumers and their Personal Information.

Personal Information We Collect

We may collect, and in the twelve (12) months prior to the “Last Updated” date of this CCPA Policy have collected, the following categories of Personal Information:

  • 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, and other similar identifiers.
  • Additional data subject to Cal. Civ. Code § 1798.80, including financial information such as credit card numbers.
  • Commercial information such as products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Internet and other electronic network activity information, including information regarding interaction with our websites, applications or advertisements.
  • Professional or employment-related information, such as employer or title.
  • 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.

Information you provide to us directly

We collect these categories of Personal Information from the following categories of sources:

  • Directly from you, including when you provide information to us
  • Indirectly from you, such as when we automatically collect technical and usage information through our Websites
  • Third-party websites, including social networks such as LinkedIn, Facebook, and Twitter
  • Government entities
  • Consumer data resellers

Purposes for Which We Collect and Use Personal Information

We may use the categories of Personal Information listed above for the purposes described in our Privacy Policy and for the following related purposes:

  • 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
  • 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
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Undertaking internal research for technological development and demonstration
  • 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
  • To develop, improve, and deliver marketing and advertising.
  • For internal operational uses such as research, analytics, development, audits, and security.
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy.
  • 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.
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
  • For any other purpose described to you when collecting your Personal Information at or before the time of collection.

Sharing of Personal Information

As described in our Privacy Policy, we may share your Personal Information with the following categories of third parties:

  • Our affiliated companies
  • Our service providers
  • Advertisers and other marketing partners
  • Our business partners
  • Other third parties to protect our legal rights or comply with legal requirements.
  • Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Other third parties involved in a merger, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Other third parties with your prior consent.

In the twelve (12) months prior to the “Last Updated” date of this CCPA Policy, we may have disclosed to third parties the following categories of your Personal Information, which are described in more detail above, for a business purpose:

  • Identifiers
  • Additional data subject to Cal. Civ. Code § 1798.80
  • Commercial information
  • Internet and other electronic network activity information
  • Professional or employment-related information
  • Inferences

In the twelve (12) months prior to the “Last Updated” date of this CCPA Policy, we have not sold Personal Information. We do not sell Personal Information, and we do not have actual knowledge that we sell Personal Information about individuals under the age of 16.

California Consumer Privacy Rights

You may have certain choices regarding our use and disclosure of your Personal Information, as described below.

Access and Data Portability Rights

You may 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 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 disclosed your Personal Information for a business purpose, a list of the categories of third parties who received a disclosure for a business purpose that identifyies the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You may have the right to request that we delete your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

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 an agent that you provide written permission to act on your behalf, may make a verifiable consumer request related to your Personal Information. If an authorized agent makes a request on our behalf, prior to responding we may require the authorized agent to present written and signed proof of authorization to act on your behalf and verify your identity or confirm the authorized agent’s permission to act on your behalf directly.

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 agent. In order to verify your request, we may require you to provide information such as your first and last name, email address, zip code, and any other information necessary for us to verify your request.
  • 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. However, if you have a password-protected account with us we may consider requests made through that account sufficiently verified when the request relates to Personal Information associated with that specific account.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your Personal Information that is readily usable.

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 we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

Non-Discrimination

Subject to certain exceptions, you have the rights not to receive discriminatory treatment for exercising your access, data portability, and deletion rights described above.

Shine the Light

California’s “Shine the Light” law (California Civil Code Section § 1798.83) permits Consumers with whom we have an established business relationship to request certain information regarding our disclosures of certain types of their personal information (as defined by that law) during the preceding year, if any, to third parties for those parties’ own direct marketing purposes. To make such a request, please email us at privacy@ziftsolutions.com.

Changes to this CCPA Policy

We may revise this CCPA Policy from time to time to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. When we make changes, we will post the updated policy to our Websites and update the “Last Updated” date.

Links to other sites

Please note that our Websites and Applications may contain links to other Internet sites. For example, if you apply for a job using the careers feature linked to our site, please be advised that feature is a separate website not subject to this Privacy Policy. Any information that you post to or otherwise provide to any such Internet site are not subject to this Privacy Policy. Zift Solutions does not control any Internet site other than our Websites and Applications and thus is not responsible for the privacy practices, privacy statements, or content of these other Internet sites.

Contacting Us

To ask questions about this CCPA Policy and our privacy practices, please contact us at privacy@ziftsolutions.com.