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Effective Date: 03/01/2024
Last Updated: 03/01/2024
This privacy notice supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumer” or “you”). We adopt this Policy to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.
Categories of Information We Collect
We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers: | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other contact information. | YES |
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, address, telephone number, banking information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Race, ethnicity, religious or philosophical beliefs, age, or sex (including gender). | YES |
D. Commercial information. | Records products, services or services purchased, obtained, or other purchasing or consuming histories or tendencies. | YES |
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, 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, operating system and web browser information. | YES |
G. Geolocation data. | Physical location or movements. | YES |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
I. Professional or employment-related information. | Current job history or job title. | YES |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
K. Inferences drawn from other Personal Information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
L. Sensitive Personal Information | Race, ethnic background, social security numbers, driver’s license, state identification card, passport number, or precise geolocation. | YES |
Personal information does not include:
How We Collect Personal Information
We use different methods and sources to collect personal information about you including:
Aggregated Information:
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Information”). Aggregated Information could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity. For example, we may aggregate your website usage data to calculate the percentage of users accessing our websites and Services. However, if we combine or connect Aggregated Information with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Using of Your Personal Information
We may use your information for the purpose of conducting our business operations including, for the following purposes:
In the preceding twelve (12) months, we have used your personal information from the following categories for business purposes:
Disclosing of Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
Sale of Personal Information/Targeted Advertising
In the preceding twelve (12) months, we have not sold any personal information or shared any personal information for cross-context behavioral advertising/targeted advertising.
Sensitive Personal Information
Sensitive personal information means personal information that reveals (A) a consumer’s social security number, driver’s license, state identification card, or passport number; (B) a consumer’s 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; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) consumer’s genetic data; (G) biometric information for the purpose of uniquely identifying a consumer; (H) personal information collected and analyzed concerning a consumer’s health; or (I) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
In the preceding twelve (12) months, we may have collected and used the following sensitive personal information:
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You 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 following:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers/contractors to delete) your personal information from our records unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Correction Requests
If you think some of the personal information we have about you is incorrect, you have the right to request that we correct the personal information in compliance with the California Consumer Privacy Act.
Your Right to Opt-Out of Sale or Sharing Your Information
We do not sell or disclose personal information with third parties that would be considered a “sale” under the CCPA. Since we do share your personal information for targeted advertising or cross-context behavioral advertising, you are opted-out of “sale” or “sharing” (as defined by the CCPA) your personal information.
Retention Criteria
We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information, including sensitive information, vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retain your personal information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims. Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:
Exercising Access, Data Portability, Deletion, and Correction Rights
To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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 a business relationship with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address from which you submit it.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Notice of Financial Incentives
We do not offer financial incentives or pricing discounts for providing your personal information.
Contact Information
If you have any questions or comments about this notice, our Privacy Notice, any other notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Address:
Attn: Legal Department
WorldLink
3880 Parkwood Blvd, Suite 204
Frisco, TX 75034
Email: privacy-request@worldlink-us.com
Phone: 1-800-673-6155
Consumer Access Request: Consumer Access Request
0149871.0753559 4875-9572-1382v2