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PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS: CALIFORNIA PRIVACY RIGHTS

Last Modified:  December 31, 2019

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT  

This Notice for California Residents supplements the information contained in TowerData’s Privacy Policy and applies solely to California residents as defined in the California Consumer Privacy Act of 2018 (“CCPA”). 

In the sections below, we describe (as required by the CCPA):

  1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from, and what our business purposes are for collecting and using it.
  2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
  3. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California residents’ personal information:

1. OUR COLLECTION OF PERSONAL INFORMATION

This section describes the types of Personal Information that we collect, the types of sources we collect it from, and what our business purposes are for collecting and using it.

Categories of Information We May Collect

Depending on how you interact with us, TOWERDATA may collect the following categories of Personal Information:

  • Identifiers: name, email address,  postal address, telephone number, IP address and mobile advertising ID;
  • Categories of personal information described in CA Civil Code § 1798.80(e): name, address and telephone number;
  • Characteristics of protected classifications under California or US law: gender and marital status;
  • Commercial information, such as home or auto ownership, products or services purchased, obtained or considered or other purchasing or consuming histories or tendencies;
  • Internet activity information, such as IP address, user agent and interactions with websites and emails;
  • Geolocation information: postal address and IP address;
  • Demographic information, such as age, gender, presence of children in the household and income;
  • Inferences drawn from the information above, such as gender and behavioral tendencies; and
  • Professional or employment-related information, as provided by you when applying for a job with TOWERDATA.
How We Collect Information - Sources

Here are our sources of information from and about California residents. We collect

  • identifiers, commercial information, internet activity information and geolocation information from consumers when they interact with our website or emails or staff.
  • professional or employment-related information from job applicants and from background check services when applicants apply for a job with TOWERDATA.
  • identifiers, demographic information, commercial information and geolocation information from data compilers and consumer data resellers.
  • identifiers, Internet activity information, geolocation information and inferences from data compilers, affiliate networks, advertising networks, advertising technology companies and business-to-business companies.
How We May Use Information

We may use Personal Information for the following business purposes:

  • For website operations, content improvements, testing, research, analysis and product development;
  • To provide users with customer service and to respond to inquiries;
  • To provide users with email and direct mail messages concerning certain of our products and/or services that we believe may be of interest to you;
  • To maintain suppression or opt-out lists so that people are not contacted when they have asked not to be;
  • To detect, investigate and respond to any fraudulent or malicious activity or any other activity we determine is or may be a violation of our Terms, Policy, existing laws, rules and regulations;
  • To create, improve and provide to our clients, who are generally businesses and non-profit organizations, a range of data services products that assist them in marketing to their own customers and prospective customers. We describe these products and services in the How We Use the Information Section of this Privacy Policy;
  • To augment Personal Information by enhancing it with other data we collect or is provided to us by third parties to enable us, for example, to gain deeper insights into our users or improve our services;
  • As necessary or appropriate to protect our rights, property or safety and that of our clients, advertisers, service providers, data providers and others;
  • If we are sold, merge with a third party, are acquired or are the subject of bankruptcy proceedings, your Information may be shared with the applicable third party(ies); if we are involved in one of these transactions, users will be notified via email or a Policy update on our Website of any change in ownership or uses of your Information, as well as any choices that you may have regarding your Information; and
  • To respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims or when we determine it is necessary to comply with applicable laws or regulations.
2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION 

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers.  The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months. 

Category Category of Businesses We Share With Whether We Sold This Category of Personal Information in the Last 12 Months
Identifiers, e.g., name;postal address; IP address; email address; or similar identifiers. Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, content publishers, non-profit organizations, business-to-business companies, advertising networks, data analytics providers, and social networks (referred to below as “Customer Categories”).  
Characteristics of protected classifications under California or US law.  E.g., gender and marital status Customer Categories

Yes

Commercial or transactions information.  E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Customer Categories Yes
Internet or other electronic network activity information.  E.g., browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement. Customer Categories Yes


3. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.  

Right to request access to your personal information

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell. You may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information.  

Right to Opt-out of the sale of your personal information

California residents have the right to opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.”

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum, titled Our Disclosure and Sale of Personal Information.

If you would like to opt-out of the sale of your Personal Information, you may do so on our opt-out page.

Right to request deletion of your personal information

California residents have the right to request that we delete any personal information that we collected directly from you, such as if you have been a customer of ours. Please note that this is different from your right to “opt out” of us selling your personal information, which is described above. Also note that we do not generally collect personal information directly from consumers.

However, we may retain personal information  for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (d) to comply with law enforcement requests pursuant to lawful process, (d) for our own internal purposes reasonably related to your relationship with us, or (e) to comply with legal obligations.  

How to exercise your access and deletion rights

California residents may exercise their California privacy rights by submitting your request using our California rights form; by sending an email to privacy@towerdata.com; by mailing TowerData, Attn: Privacy Officer, 33 Irving Place, 3rd Floor, New York, NY 10003; or by calling 866-377-3630. You may request access or deletion of your information up to two times within a 12-month period.

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you – when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you, you will need to provide certain identifiers to verify your California residency and verify your identity and confirm you are the person you claim to be. These identifiers may include your full name, email address, postal address, government issued ID, and a picture of yourself holding your ID. You may also need to go through challenge questions for knowledge-based authentication. This information will only be used for verification purposes. We will delete this information as soon as practical after processing your request, except as required to comply with CCPA.

Once we have verified your identity, we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories. 
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.   
  • Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”:  because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences.  In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.
  • Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you.  Certain information may be exempt from such requests under applicable law.  

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

Right to nondiscrimination  

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.   

Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).   

Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.


Contact Us

If you have questions related to this policy, or regarding TOWERDATA’s products or services, please contact us at:

TowerData, Inc.
Attn: Privacy Officer
33 Irving Place, 3rd Floor
New York, New York 10003
privacy@towerdata.com