The California Consumer Privacy Act (CCPA) is a state-wide data privacy law that regulates how businesses all over the world are allowed to handle the personal information (PI) of California residents. The effective date of the CCPA is January 1, 2020.

We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a detailed disclosure about what categories of Personal Information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. It will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses.

If you are a California resident and would like a copy of the disclosure, please submit an email request to privacylens@newherotech.com. Remember to include the words “CCPA” in the subject line and your name, street address, city, state, and zip code in the body of the email.

The Definition Of Personal Information Under The CCPA

Personal information is information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other personal information that could create a profile about your preferences and characteristics.

Information We Collect From California Consumers

We collect the following categories of Personal Information:

• Identifiers: full name, home address, unique personal or online identifier, Internet Protocol (IP) address, email address, phone number etc.
• Legally Protected Characteristics: Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) etc.
• Commercial information: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies etc.
• 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, face prints, and voice prints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
• network activity: browsing history, information regarding a consumer's interaction with a website, or online advertisement etc.

P.S. Some of the categories may overlap with each other.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To satisfy or achieve the intent for which the information is provided. For example, if you provide us with Personal Information in order to access our Services.
• To provide you with information or services that you request from us
• To send you email updates and other reminders regarding our Services, events or news that may be of interest to you
• To carry out our responsibilities and enforce our rights arising from any contracts entered into between you and us
• To improve our Site and present the contents to you
• For testing, research, analysis and product/service development
• As necessary or appropriate to protect the rights, property or safety of us, our Users, or others
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
• As described to you when collecting your Personal Information or as otherwise set forth in the California Consumer Privacy Act
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without your prior permission.

Sharing Personal Information

We may share your Personal Information with a third party for a business purpose. When we do, we enter 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.

We have shared the following categories of Personal Information with third parties, including our affiliates and our service providers, for a business purpose within the last twelve months:

• Identifiers
• California Customer Records personal information categories
• Commercial information
• Internet activity
• In the preceding twelve (12) months, we have not sold any Personal Information

Your Rights Under The CCPA

The CCPA provides consumers who are California residents with specific rights regarding their Personal Information.

1. 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 categories of Personal Information we collected about you
• The categories of sources for the Personal Information we collected about you
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal information we collected about you (also called a data portability request)
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of each category of recipient obtained; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

2. 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 to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers in the following ways:

• To complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
• To debug products to identify and repair errors that impair existing intended functionality
• To exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
• To comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
• To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent
• To enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
• To comply with a legal obligation
• To make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Exercising Access, Data Portability, and Deletion Rights

To exercise your rights of access, data portability, and/or deletion described above, please submit a verifiable consumer request email at privacylens@newherotech.com

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 also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice a year. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or your authorized representative. It also needs to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we cannot respond to your request or provide you with Personal Information. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

4. Response Timing and Format

We are endeavoring to answer you within 45 days of receiving a verifiable customer request. If more time is needed, we will let you know why and give you a deadline extension in writing. We'll respond you by means of letters or emails. We will only provide disclosures for the 12-month duration preceding our receipt of your verifiable letter.

If necessary, we will also clarify why we are unable to fulfill your request in the response. We will include your Personal Information in an accessible format for data portability requests, allowing you to transmit the information from one entity to another.

Unless your verifiable customer request is excessive, repetitive, or manifestly unreasonable, we will not charge a fee to process or respond to it. If we think a fee is necessary, we will explain why we made that decision and provide you with a cost estimate before we complete your submission.

Nondiscrimination

Everyone qualified to exercise the CCPA privileges will be treated fairly here. Unless permitted by the CCPA, we will not:

• Refuse to offer you services
• Provide you services of an inferior quality
• Charge you different prices or rates for services

DATE LAST MODIFIED: Dec 21, 2024