This overview will provide a plain-spoken statement of USADATA's approach to and obligations under CCPA. Unless we indicate otherwise, the terms used in this Policy have the meanings set forth in the CCPA.
USADATA is not in the business of creating or maintaining permanent databases of consumer personal information. Instead, USADATA, in connection with providing mailing list, telemarketing list, email list, and data hygiene and enhancement services to a client, collects consumer personal information directly from that client, or from a limited set of reputable third-party data sources, and uses that information to service the client. USADATA does not retain, use, or disclose personal information collected to provide services to one client to provide services to other clients, or for its own commercial purposes, though it may use such information to build or improve the quality of its services and/or to detect data security incidents, or protect against fraudulent or illegal activity. With limited exceptions, USADATA securely destroys all personal information collected at the conclusion of each client project. The categories of personal information USADATA collects, and the purposes for which it uses that information, are described in detail below.
USADATA is not a "business," as that term is defined in the CCPA. Instead, it is a "service provider" to certain of its clients. Because it is a service provider, USADATA cannot act upon consumer requests to "know" or "delete" their personal information. In the event that we receive such requests, we will advise the requestor of this fact. USADATA does not, on behalf of any business, sell the personal information of any consumer whom USADATA knows has opted-out of the sale of their personal information by that business.
We may collect personal information in a variety of categories to carry out our business, operate the Site, comply with the law, and other purposes described in the CCPA. Specifically, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and account name||YES1|
|Social Security number, driver's license number, passport number, or other similar identifiers.||NO|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Signature, Social Security number, physical characteristics or description, passport number, driver's license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other personal financial information, medical information, or health insurance information.||NO|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, and veteran or military status.||YES1|
|Medical condition, physical or mental disability, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, and genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES1|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements.||YES1|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES2|
|J. Education information.||Education level||YES1|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES1|
The Company may add to the categories of PI it collects. We will notify you in the event we do so. Personal information does not include certain types of information, including without limitation:
We obtain the categories of personal information listed above from the following categories of sources:
We may use the personal information we collect for one or more of the following business and/or commercial purposes:
We will not use your personal information for a materially different purpose than those identified above without notifying you of this new use and obtaining your explicit consent.
In the past twelve (12) months, we have sold or disclosed for a business purpose the following categories of personal information to the following categories of third parties:
|CATEGORIES OF PERSONAL INFORMATION SOLD OR DISCLOSED FOR BUSINESS PURPOSES||CATEGORIES OF THIRD PARTIES TO WHOM SOLD OR DISCLOSED|
|Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.||Sold to clients to whom we provide certain of our services. Clients may include resellers such as printers and agencies or end clients in a variety of industries such as financial services or retail. Disclosed to third-parties we interact with in connection with the services we perform, such as data brokers that provide mailing lists, data enhancement services and/or email, digital or social media campaign services.|
|Protected classification characteristics under California or federal law||Sold to clients to whom we provide certain of our services. Clients may include resellers such as printers and agencies or end clients in a variety of industries such as financial services or retail. Disclosed to third-parties we interact with in connection with the services we perform, such as data brokers that provide mailing lists, data enhancement services and/or email, digital or social media campaign services.|
|Commercial information||Sold to clients to whom we provide certain of our services. Clients may include resellers such as printers and agencies or end clients in a variety of industries such as financial services or retail. Disclosed to third-parties we interact with in connection with the services we perform, such as data brokers that provide mailing lists, data enhancement services and/or email, digital or social media campaign services.|
|Professional or employment-related information||Disclosed to third-parties that provide human resources support services.|
|Inferences drawn from other personal information.|
You as a California resident have the right to request that businesses disclose certain information to you about their collection, use, disclosure, and/or sale of your personal information over the past 12 months. Specifically, you have the right to request that these businesses disclose to you:
Because it is a service provider, USADATA cannot act upon consumer requests to know or delete their personal information. In the event that we receive such requests, we will advise the requestor of this fact. USADATA does not, on behalf of any business, sell the personal information of any consumer whom USADATA knows has opted-out of the sale of their personal information by that business.
We will confirm receipt of your Request within 10 business days, and will endeavor to respond to your Request within forty-five (45) calendar days (though, in some instances, we may require up to ninety calendar (90)
days to respond, in which case we will notify you that we need the applicable extension, and explain the basis for it). As a service provider, we cannot respond to requests to know or delete your personal
information, and will notify you of that fact upon receipt of your request. In the event that a business, on whose behalf we sell your personal information, advises us that you have opted-out of such sales, we will
cease selling your information on behalf of that business.
In the event we cannot comply with your request, in part or in full, we will provide a corresponding explanation.
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.
Depending on the jurisdiction in which you are located, you may have the right to opt-out of the sale of your personal information. In most cases, USADATA ("we" or the "Company") does not sell personal information,
and in no circumstances does it sell personal information obtained from its clients, employees, job applicants, website and app users, or office visitors. Nor does the Company sell the personal information of minors
that it knows are under 16 years of age. We do, however, offer certain services that involve the provision of information to our clients in a manner that may be deemed a "sale" under applicable law. For more
To exercise your right to opt-out of the sale of your personal information, please submit your request to us by emailing email@example.com or by postal mail:
Attn: CCPA / Privacy
875 Third Ave, Ste 6A
New York, NY 10022
USADATA does not collect the personal information subject to this notice directly from consumers, but instead collects it from a limited set of reputable third-party data sources. Upon receipt of your opt-out request, USADATA will promptly advise those data sources of your request so that they can take appropriate action to comply with it. You can also submit opt-out requests directly to these providers at the following links:
You may use an authorized agent to submit an opt-out request on your behalf if you have provided the authorized agent signed permission to do so. We may deny an opt-out request from an agent that does not submit proof that they have been authorized to act on your behalf or if we reasonably believe that the request is fraudulent. Otherwise, we will fulfill your request within a reasonable timeframe in accordance with applicable law.
Minors may not use our websites or submit information to us. We do not intentionally collect information about minors.
Additionally, USADATA does not have actual knowledge that it has sold the personal information of minors under 16 years of age.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on our Site and update the Policy’s effective date. Such changes will take effect immediately upon posting to the Site and will apply to your use of the Site and the Company's practices concerning personal information after the new effective date reflected in the Policy. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.
California's "Shine the Light" law (Civil Code Section § 1798.83) provides California residents with the right to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us at the following email address: firstname.lastname@example.org.
If you have any questions or comments about this Policy, or about our privacy policies and practices in general, please do not hesitate to contact us at:
Request for Information: email@example.com
Phone Number: (800) 395-7707
Attn: Privacy & Compliance
875 Third Ave, Ste 6A
New York, NY 10022
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