California Privacy Policy | American Briefing

California Privacy Policy

Privacy Policy Applicable

To California Residents

 

Effective Date: February 2022

Last Updated: February 2022

 

This Privacy Policy Applicable To California Residents (“California Privacy Policy”) is provided as a supplement to Pop Acta Media LLC’s (“Company”, “us”, “we”) standard Privacy Policy and includes information on how you can exercise your rights under the California Consumer Privacy Act (“CCPA”).  Please note, this Policy only applies to those residents of the State of California (referred to as “consumers” or “you”).  Our California Privacy Policy and standard Privacy Policy may be collectively referred to herein as the “Privacy Policies.”

 

  1. COLLECTION OF PERSONAL INFORMATION

 

  • Categories of personal information that we collect about California consumers

 

We collect information that identifies, relates to, references, reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).  Personal information does NOT include publicly available information from government records or deidentified or aggregated consumer information.

 

We may have, however, collected the following categories of personal information from consumers within the last twelve months and may continue to do so in the future.  Please note that while some of the information in the provided identifiers was collected, a response of “This information was collected” does not mean that all types of provided information were collected.  As an example, while we may have collected your name and telephone number, we have not collected your passport number, bank account number, credit card number, medial information, etc.

 

  • Category A (Identifiers)
    • Examples of this type of information include: a name, alias, mailing address, personal identifier, online identifier, IP address, email address, account name, etc.
    • This information was and is collected.
  • Category B (Personal Information)
    • Examples of this type of information include: name, signature, physical characteristics or description, address, phone number, financial information, identification information (driver’s license, passport number, insurance policy number, credit and/or debit card number, any other financial information, medical information, or health insurance information.
    • Some of this information was and is collected.
  • Category C (Protected classification characteristics under California law)
    • Examples of this type of information include: age (40 years or older), 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.
    • Some of this information was and is collected.
  • Category D (Commercial information)
    • Examples of this type of information include: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    • Some of this information was and is collected.
  • Category E (Biometric information)
    • Examples of this type of information include: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
    • This information was not and is not collected.
  • Category F (Internet or other similar network activity)
    • Examples of this type of information include: browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    • Some of this information was and is collected.
  • Category G (Geolocation data)
    • Examples of this type of information include: physical location or movements.
    • Some of this information was and is collected.
  • Category H (Sensory data)
    • Examples of this type of information include: audio, electronic, visual, thermal, olfactory, or similar information.
    • This information was not and is not collected.
  • Category I (Professional or employment-related information)
    • Examples of this type of information include: current or past job history or performance evaluations.
    • This information was not and is not collected.
  • Category J (Non-public education information per the Family Educational Rights and Privacy Act)
    • Examples of this type of information include: education records 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.
    • This information was not and is not collected.
  • Category K (Inferences drawn from other personal information)
    • Examples of this type of information include: profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • Some of this information was and is collected.

 

  • Categories of sources of personal information from which we collect

 

We receive personal information from a variety of sources, including directly from you, your devices, or from our partners or third parties.  The categories of sources from which personal information is collected includes:

 

  • Directly from you. This means you directly provided the information to us by, for example, completing a form.
  • Indirectly from you. This means information was gathered by, for example, observing your actions and clicks on our website.
  • From third-parties such as commercial data providers and data analytics providers.

 

1.3       Business or commercial purpose for collection

 

We may use, sell, rent, or otherwise share or disclose information you provide to us or that we collect through the use of our website for one or more of the following purposes:

  • To fulfill or meet the need that prompted you to provide the given information. For example, if you shared information with us to opt-in to receive one of our newsletters, we will use the provided information to send you the requested content.  We may also save information you provide us to continue sending you requested information and as otherwise provided herein.
  • Subject to applicable contractual or governing legal restrictions, to provide the information in connection with the sale or exchange of user information and related data to a data broker, political committee, or other non-profit or for-profit entity that is similarly aligned organizations.
  • To provide support, personalize, and/or develop our website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, transactions, and prevent transaction fraud.
  • To provide you with support and to respond to your inquiries, including to investigate your concerns and to monitor and improve our responses and services.
  • To personalize your experience when visiting our website and to deliver content and products and services relevant to your interests. This may include delivering targeted offers and ads through our Website, third-party sites, and via email or peer-to-peer text messaging.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases, and other technology assets, and business.
  • For texting, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when you provided and we collected or personal information, or as otherwise set forth in the CCPA.
  • 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 about our Website, users, and consumers is among the assets transferred.

 

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

 

  1. CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR A BUSINESS PURPOSE OR “SOLD”

 

We may share your personal information by disclosing it to a third party for a business purpose or to support like-minded organizations for a fee consistent with our Privacy Policies.  We only make these business disclosures as described in this policy and under written contracts that describe the purposes for which the information is given, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performance of the agreed upon contractual services or as described in these Privacy Policies.

 

The following Table 2.1 lists the categories of personal information disclosed for a business purpose and the categories of recipients who may have received this personal information.  Please note that not every one of the following categories may apply to your personal information.

 

For more information on your personal information sales rights, please see the section entitled “CCPA Rights.”

 

 

 

Table 2.1

 

Category of Personal Information Disclosed For A Business Purpose Categories of Recipients
·       Category A (Identifiers)

·       Category B (Personal information)

·       Category C (Protected classification characteristics under California law)

·       Category D (Commercial information)

·       Category F (Internet or other similar network activity)

·       Category G (Geolocation data)

·       Category K (Inferences drawn from other personal information)

·       Data brokers or aggregators

·       Service providers

·       Affiliates

·       Partners

·       Parent or subsidiary organizations

 

The following Table 2.2 lists the categories of personal information “sold” and the categories of recipients who may have received this information.  The CCPA’s definition of “sale” is broad.

 

Table 2.2

 

Category of Personal Information “Sold” Categories of Recipients
·       Category A (Identifiers)

·       Category B (Personal information)

·       Category C (Protected classification characteristics under California law)

·       Category D (Commercial information)

·       Category F (Internet or other similar network activity)

·       Category G (Geolocation data)

·       Category K (Inferences drawn from other personal information)

·       Data brokers or aggregators

·       Service providers

·       Affiliates

·       Partners

·       Parent or subsidiary organizations

 

The CCPA prohibits the selling of personal information unless you have been provided explicit notice and the opportunity to opt-out of further sales.  In the event your personal information will be sold, this provision shall be updated to reflect the sale and provide you with information as to how to opt out of such sales.

 

We do not collect, possess, share, or sell deidentified patient information.

 

  1. CHILDREN

 

We do not knowingly collect, disclose, or sell the personal information of consumers under the age of 16.

 

  1. CCPA RIGHTS

 

The CCPA provides various rights to California consumers regarding their personal information.  These include rights to access, deletion, opt-out, and non-discrimination.  This section describes each CCPA right and explains how California consumers can exercise those rights under the CCPA.  The CCPA does not currently extend certain privacy rights to consumers for personal information collected from the business in the employment-related context (such as from employees or job applicants).

 

For the Company to fulfill your request, you must provide sufficient information for us to reasonably verify that you are the consumer from whom we collected the personal information.  The information you send us to verify your identity will be used for this purpose only.  If we are unable to verify your identity or if we suspect fraudulent activity, we may decline to comply with your request.

 

We will make commercially reasonable efforts to identify your personal information that we collect, process, store, disclose and otherwise use and to respond to your requests.  We reserve the right to charge a reasonable fee, or decline to act upon a request, if it is excessive or overlying burdensome.  If we deny your request, we will explain the reasons in our response.

 

  • Right to access (also called a “request to know”)

 

  • The right to access
  • California consumers have the right to request that we disclose the personal information that we collect, use, disclose, and sell. This includes the right to request:
    • The categories of personal information that 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 information
    • The categories of third parties with whom we share that personal information
    • If we sold or disclosed your personal information for a business purpose, we will provide two separate lists detailing
      • Sales, including the identification of personal information categories that were purchased by the recipient, and
      • Disclosures for a business purpose, including the identification of the personal information categories that each category of recipient received and/or obtained.
    • The specific pieces of personal information we collected about you (also known as a data portability request)
  • How to exercise the right to access
    • Two ways to submit a request:
      • Emailing us at: [email protected]
      • Visiting https://popacta.com/contact-us/?site=americanbriefing.com and clicking the link at the bottom of the page titled Contact
    • We are required to verify the identity of everyone to whom we release personal information. Please provide us with the following information in your request:
      • Your first name, last name, address, and e-mail address;
      • If you are an authorized agent submitting a request on behalf of a California consumer, proof that you are authorized to act on his/her behalf; and
      • A description of your particularized request that allows to understand, evaluate, and process your request.
    • Note, only you or someone authorized to act on your behalf is permitted to make or submit such a request. Requests may be submitted twice within a twelve (12) month period.
    • For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights. If we are unable to verify your identity or your authority to submit such a request, we will be unable to process it.  If personal information is provided in submitted a request, that information will only be used to verify identity and a corresponding data entry.  Such personal information will not be used for any additional purpose.
  • Response timing and format
    • We make all reasonable efforts to confirm receipt of your request within ten (10) business days. If you have not received a response from us within this timeframe, please email [email protected].
    • Once a request has been received and verified by us, we work to process all such requests within a reasonable timeframe. If a request will take longer than forty-five (45) days to process, you will receive an update from us informing you of the reason for the delay and the required extension period in writing.  This update will either be mailed to you or sent via email.
    • Please note, any disclosures by us in response to a request will only encompass the twelve (12) month timeframe that precedes your request. If we are unable to comply with your request, you will receive a response indicating the general reasons why.
    • For those data portability requests, we will provide you with such information in a manner of our choosing, but that is reasonably anticipated to be readily usable by you. Such format may, for example, be an Excel spreadsheet or pdf.
    • There are no fees associated with processing verified consumer requests unless we reasonably determine, in our sole discretion, that such requests are excessive, repetitive, or manifestly unfounded. If we ultimately determine a fee is warranted due to the above, you will receive a notice indicating why that decision has been reached and provide you with the anticipated cost for processing such request.  You may then, in your sole discretion, determine whether you want to proceed with such request.

 

4.2       Right to Delete

 

  • The right to delete
    • Subject to some exceptions, California consumers have the right to ask that we delete the personal information that we collected from you. Once we have received your requests and confirmed your identity, your request will be reviewed and processed to determine whether an exception applies that would permit us to retain your information.  Your request may be denied if retention is required to allow us or our service providers to:
      • Complete the transaction for which the personal information was collected in the first place, provide a good or service, take actions reasonably anticipated and related within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      • Detect security incidents, prevent against malicious, deceptive, fraudulent, or illegal activity, or prosecute those who engage in or are responsible for such activities.
      • Debug products to identify and repair errors that may decrease or otherwise negatively effect the intended functionality of the offered services.
      • Exercise free speech, ensure the right of another participant to exercise their free speech rights, or to exercise any other right provided for or permitted by law.
      • Comply with the California Electronic Communications Privacy Act or other applicable federal law.
      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • Comply with a legal obligation.
      • Make other internal and lawful uses of that information that are compatible with the context in which you provided such information.
    • Please note, as we are not in control of such service providers, we will not be responsible should such providers fail to delete such information as requested by us. Any such deletion requests will be processed within a reasonable timeframe.  Your patience is appreciated.
  • How to exercise the right to delete
    • Two ways to submit a request:
      • Emailing us at: [email protected]
      • Visiting https://popacta.com/contact-us/?site=americanbriefing.com and clicking the link at the bottom of the page titled Contact
    • Please provide us with the following information in your request:
      • Your first name, last name, address, and e-mail address;
      • If you are an authorized agent submitting a request on behalf of a California consumer, proof that you are authorized to act on his/her behalf; and
      • A description of your particularized request that allows to understand, evaluate, and process your request.
    • Note, only you or someone authorized to act on your behalf is permitted to make or submit such a request. Requests may be submitted twice within a twelve (12) month period.
    • For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights. If we are unable to verify your identity or your authority to submit such a request, we will be unable to process it.  If personal information is provided in submitted a request, that information will only be used to verify identity and a corresponding data entry.  Such personal information will not be used for any additional purpose.
  • Response timing and format
    • We make all reasonable efforts to confirm receipt of your request within ten (10) business days. If you have not received a response from us within this timeframe, please email [email protected].
    • Once a request has been received and verified by us, we work to process all such requests within a reasonable timeframe. If a request will take longer than forty-five (45) days to process, you will receive an update from us informing you of the reason for the delay and the required extension period in writing.  This update will either be mailed to you or sent via email.
    • Please note, any disclosures by us in response to a request will only encompass the twelve (12) month timeframe that precedes your request. If we are unable to comply with your request, you will receive a response indicating the general reasons why.
    • There are no fees associated with processing verified consumer requests unless we reasonably determine, in our sole discretion, that such requests are excessive, repetitive, or manifestly unfounded. If we ultimately determine a fee is warranted due to the above, you will receive a notice indicating why that decision has been reached and provide you with the anticipated cost for processing such request.  You may then, in your sole discretion, determine whether you want to proceed with such request.

 

  • Right To Opt Out

 

  • The right to opt out
    • California consumers have the right to opt-out of any “sale” of their personal information. As mentioned, the CCPA’s definition of “sale” is broad.
    • California consumers who have elected to opt-in to personal information sales retain the right to opt-out of such sales at any time.
  • How to exercise the right to opt out
    • If you wish to exercise this right, you or your authorized representative may submit a request to us by visiting this website: https://popacta.com/contact-us/?site=americanbriefing.com. You do not need to create an account with us to exercise your opt-out rights and any information provided in the exercise of such rights will only be used to review and comply with your request.
    • If you submit an opt-out request, we will not ask you again within a twelve (12) month period whether you would like to opt back in to such personal information sales. If you change your mind during this twelve (12) period, you may opt back in at any time by emailing us at [email protected].

 

  • Right to non-discrimination

 

You will not be discriminated against by us for exercising any of your CCPA rights.  Unless authorized by the CCPA, we will not engage in any of the following:

  • Denying you goods or services.
  • Charging you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Providing you a different level or quality of goods or services.

 

We do not use the fact that you have exercised, or requested to exercise, any CCPA rights for any purpose other than facilitating a response to your request.

 

  1. DO NOT TRACK

 

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals.  Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.  For more information about our privacy practices, please see our standard Privacy Policy.

 

  1. CALIFORNIA’S “SHINE THE LIGHT” LAWS

 

If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.  We do not share personal information with third parties for their own direct marketing purposes without obtaining your consent or providing the ability to opt-out.

 

  1. CHANGES

 

We reserve the right to amend this California Privacy Notice at our discretion, at any time, and for any reason.  When this California Privacy Notice is amended, the revised notice will be posted on our Website and the effective date of the notice will be updated.  You hereby recognize and agree that your continued use of our Website after such changes take effect constitutes your acceptance of the revised terms.

 

  1. CONTACT INFORMATION

 

If you have any questions or comments about this California Privacy Notice, how we collect and use provided information described in this and our standard Privacy Policy, your choices and rights regarding our use of such information, or wish to exercise your rights under California law, please contact us using one of the methods provided below:

  • Email: [email protected]
  • Website Contact Form: https://popacta.com/contact-us/?site=americanbriefing.com

If you need access to this California Privacy Notice through alternative means, please contact us as provided above and we will work to accommodate such request.