CCPA CONSUMER
PRIVACY ACT (CCPA)
NOTICE
CALIFORNIA CONSUMER PRIVACY ACT (CCPA) NOTICE
Pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), we provide this California Consumer Privacy Act Notice (the “Notice”) to California residents (“consumers” or “you”). This Notice supplements the information provided in our Privacy Policy. This Notice applies to information that identifies, relates to, describes, or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household (collectively, “Personal Information”). This Notice does not apply to information we collect about individuals in their capacity as present or former job applicants, employees, contractors, owners, directors, or officers of Fevo.
CATEGORIES OF PERSONAL INFORMATION
In the following charts, we identify (1) the categories of Personal Information and Sensitive Personal Information (as listed in the CCPA) that we plan to collect and use, and have collected and used in the past 12 months; (2) the categories of parties to which we have disclosed each category of Personal Information or Sensitive Personal Information for our operational business purposes in the past 12 months; (3) the criteria we use to determine the retention period for each category of Personal Information or Sensitive Personal Information; and (4) the categories of Personal Information and Sensitive Personal Information we have “Sold” or “Shared” in the past 12 months, as defined in the CCPA.
“Sensitive Personal Information” refers to personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email, and text messages unless Fevo is the intended recipient of the communication; genetic data; and biometric information.
We do not sell Personal Information in the traditional sense of the word, for monetary consideration. However, because the definition[s] of “Sale” and “Sharing” under the CCPA are broad enough to potentially include the disclosure of your information to certain types of advertising and marketing partners, we provide California residents with the right to opt-out of any such Sale or Sharing of their Personal Information. We do not knowingly Sell or Share the Personal Information of anyone 16 years or younger.
Category of Personal Information Collected
Disclosed to Which Categories of Third Parties for Operational Business Purposes
Retention Period Criteria
Sold or Shared? If so, to Which Categories of Third Parties?
- Business partners with whom we jointly offer products or services, including Third Party websites and applications, such as Offer Providers (“Business partners”)
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Advertising networks
- The length of time we have an ongoing relationship with you (for example, for as long as you have an account with us or keep using the Services;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is necessary in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations)
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Advertising networks
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Advertising networks
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Business partners
- Our corporate affiliates
- Government authorities or other parties pursuant to law
Below, we provide this information related to Sensitive Personal Information:
Category of Sensitive Personal Information Collected
Disclosed to Which Categories of Third Parties for Operational Business Purposes1
Retention Period Criteria
Sold or Shared for Cross-Context Behavioral Advertising?
- Our corporate affiliates
- Government authorities or other parties pursuant to law
- Our corporate affiliates
- Government authorities or other parties pursuant to law
We also may use Sensitive Personal Information or disclose Sensitive Personal Information to service providers or other third parties for additional, specified purposes provided at the time of collection. However, you have the right to request that we limit the use or disclosure of your Sensitive Personal Information as described below.
SOURCES OF PERSONAL INFORMATION
We obtain the categories of Personal Information listed above (including Sensitive Personal Information) directly from consumers, as well as from the following categories of sources: our corporate affiliates, business partners, publicly-available databases, social media sites, and other third-party sources and organizations. We sometimes use third parties to control the collection of Personal Information through our Services. These third parties can be found in our Cookies Policy.
USE OF PERSONAL INFORMATION
We use your Personal Information for a variety of business and commercial purposes, as described in our Privacy Policy.
CCPA RIGHTS AND REQUESTS
California residents may make the following types of requests under the CCPA:
- Request to Know. You may request that we disclose the following information to you about our collection and use of your Personal Information (including Sensitive Personal Information) within the past 12 months or other CCPA-specified period: (1) the categories of Personal Information we’ve collected about you; (2) the categories of sources from which we have collected that Personal information; (3) the categories of Personal Information we have Sold, Shared, or disclosed for a Business Purpose about you; (4) the categories of third parties with whom we have Sold, Shared, or disclosed for a business purpose your Personal Information; (5) the business or commercial purpose for Selling, Sharing or disclosing Personal Information; and (6) the specific pieces of information we collected about you.
- Request to Delete. You may request that we delete certain Personal Information (including Sensitive Personal Information) we have collected from you. We may limit or deny your deletion request in certain cases, in accordance with exceptions specified in the CCPA, such as to comply with a legal obligation, complete a transaction, or prevent against fraud or other unlawful activity.
- Requests to Correct. You may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
- Requests to Opt-Out of Sale or Sharing. You may opt-out of the Sale or Sharing of Personal Information.
- Requests to Limit Use of Sensitive Personal Information. You may request that we limit our use of Sensitive Personal Information that we have collected about you to that which is necessary to perform the services that we provide to you.
How to Submit CCPA Requests
Requests to Know, Delete, and/or Correct
You may submit a Request to Know, Request to Delete, and/or Request to Correct by submitting a request through Your Privacy Choices page.
We will verify and respond to such requests consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.
Requests to Opt Out of Sale or Sharing
To opt-out of Sale or Sharing, please visit our “Your Privacy Choices” page. We also recognize the Global Privacy Control opt-out preference signal. The Global Privacy Control is available here. The Global Privacy Control is device-specific, so you may need to activate the Global Privacy Control on each device from which you access the Services.
Requests to Limit Use of Sensitive Personal Information
To request that we limit our use of your Sensitive Personal Information, please visit our “Your Privacy Choices” page, or you may submit your request using the toll-free number listed above.
Authorized Agents
To make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent.
If you are making a Request to Know, Request to Delete, or Right to Correct on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the Request to Know, Request to Delete, or Request to Correct.
Nondiscrimination
You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights. You may submit a request to appeal Fevo’s action in response to your CCPA request by submitting a request via the form on this page.
Notice of Financial Incentives
From time to time, we may offer a program, benefit, or other offering in exchange for the collection, retention, sale, or sharing of Personal Information to us (collectively, “Financial Incentive”), such as your contact information. Any discount we provide will be based upon our reasonable but sole determination of the estimated value of your Personal Information, taking into consideration, without limitation, estimates regarding anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law. We may provide additional notice of the details of the particular Financial Incentive as required, and participation in any Financial Incentive programs is on an opt-in basis. If you wish to opt-out of a Financial Incentive program on a going-forward basis, you may submit a request via the form on this page.
CALIFORNIA MINORS
Persons under the age of 18 are not permitted to access or use our Services. If you are a California resident under the age of 18 and have nonetheless accessed and used our Services in violation of applicable laws and company policy, you may request that we remove content or information you have publicly posted on any of our Services. To make such a request, please send an email with a detailed description of the specific content or information to support@fevo.com with the subject line, "CALIFORNIA MINOR CONTENT REMOVAL REQUEST." Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.
