UK

CCPA Notice

California Privacy Addendum

This addendum supplements the information contained in the Privacy Notice and applies to all customers, visitors of this website, and others who reside in the State of California. We have adopted this addendum to comply with the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020 and its implementing regulations (collectively the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Addendum.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information"). Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category Examples may include
A. Identifiers. A name, alias, user ID, username, account number, email address, phone number, postal address, IP address, email address or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Personal information categories listed in the California Customers Records Statute (i.e. name, corporate address and telephone number).
C. Protected classification characteristics under California or federal law. Protected classification characteristics (e.g. age, ethnicity, race, languages spoken, or gender) to the extent these are disclosed during the provision of services.
D. Commercial information. Records of products or services purchased, obtained, or considered.
E. Biometric information. Genetic, physiological, behavioural, and biological characteristics, or activity patterns to the extent these are disclosed during the provision of the services.
F. Internet or other similar network activity. Browsing history, search history, and information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data. Physical location or movements to the extent disclosed during the provision of services.
I. Professional or employment-related information. Current or past job history or performance evaluations.
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.

We do not collect or process Sensitive Personal Information for the purposes of inferring characteristics about consumers. We do not use or disclose Sensitive Personal Information for purposes other than those specified in section 7027(m) of the CCPRA. Such permitted purposes include the performance of services reasonably expected by an average consumer who requests those services; to prevent, detect and investigate security incidents; to resist malicious, deceptive, fraudulent or illegal actions directed at a customer; to ensure the physical safety of natural persons, to verify, maintain or improve the quality of service; and purposes that do not infer characteristics about the consumer.

For more information on where we source Personal Information and how we have used Personal Information in the past 12 months, please see paragraph 2 of the Privacy Notice.

For more information on the Personal Information we have disclosed in the last 12 months, please see paragraph 4 of the Privacy Notice.

SALE OF PERSONAL INFORMATION

In the preceding twelve (12) months, we have not sold any categories of Personal Information. We do not sell Personal Information to third parties.

YOUR RIGHTS

You may have certain rights under the CCPA. These rights are subject to certain conditions and exceptions. Your rights under the CCPA may include:

  • Right to Request to Know. You have the right to request to know the following information about our practices over the past 12 months: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which we collected the Personal Information about you; (iii) the categories of third parties with whom we shared Personal Information, (iv) the categories of Personal Information we disclosed about you and the categories of third parties to whom we sold or disclosed that particular category of Personal Information; (v) our business or commercial purpose for collecting or disclosing your Personal Information; and (vi) the specific pieces of Personal Information we collected about you.
  • You may exercise your right to request to know twice a year, free of charge. If we are unable to fulfill your request to know, we will let you know the reason why. Please note, in response to a request to know, we are prohibited from disclosing your Social Security number; driver’s license number or other government-issued identification number; financial account number; any health insurance or medical identification number; an account password, security questions, or answers.
  • Right to Request to Delete. You have the right to request that we delete the Personal Information that we have collected from you. We may deny your request under certain circumstances, such as if we need to retain your Personal Information to comply with our legal obligations or if retaining the information is necessary to complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason why.
  • Right to access and portability – You have the right to request a categorised list of the Personal Information we have collected, in a portable and readily usable format.
  • Right to Request correction. You have the right to request that we correct the Personal Information we maintain about you.
  • Right to Non-Discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way.

If you, or your authorized agent, would like to make a request to know or request to delete, you can do so by clicking here or calling us toll-free on +1 844 677 4155.

VERIFICATION

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify that you are the individual about whom we collected Personal Information. We may request additional information about you so that we can verify your identity. We will only use additional Personal Information you provide to verify your identity and to process your request.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

RESPONSE TIMING AND FORMAT

We endeavour to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

RETENTION PERIODS

For more information on how long we retain your Personal Information see section 7 of the Notice.

UPDATES TO ADDENDUM

We may change or update this CCPA Addendum from time to time. When we make changes to this Addendum, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

CONTACTING US

If you have any questions or concerns about this CCPA Addendum including exercising your data rights or would like to learn more about how we protect your privacy or need to access this Addendum in an alternative format due to having a disability, please contact us by:

Effective Date: 2 April 2024