Last Modified: December 31, 2019
In the sections below, we describe (as required by the CCPA):
The following sets forth the categories of information we collect and purposes for which we may use California residents’ 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:
Here are our sources of information from and about California residents. We collect
We may use Personal Information for the following business purposes:
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||
|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|
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.
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.
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.
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.
California residents may exercise their California privacy rights by submitting your request using our California rights form; by sending an email to firstname.lastname@example.org; 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:
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.
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.
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).
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.
If you have questions related to this policy, or regarding TOWERDATA’s products or services, please contact us at:
Attn: Privacy Officer
33 Irving Place, 3rd Floor
New York, New York 10003