LOVE™ Privacy Notice for California Residents
Effective Date: April 26, 2023
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 household (“personal information”).
Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
· Information excluded from the CCPA/CPRA’s scope like:
o Health and medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
o Personal information covered by sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
|Category of Personal Information||Specific Personal Information that may be collected||Collected?||Purpose of Collecting the personal information||Categories of sources from which the Personal Information is collected||Is this category of Personal Information shared with third parties?||Categories of third parties with which the Personal Information may be shared|
|Identifiers||Name, mailing address, email address, telephone number, IP address, and account information||Yes||To uniquely identify an individual in support of business activities||Users of the Platform||Yes||Payments, shipping, tax processing, analytics, email, advertising and retargeting, single-sign-on integration|
|Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code 1798.80(e))||Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, education, employment, employment history, bank account number or any other financial information. Some personal information included in this category may overlap with other categories||Yes||To uniquely identify an individual in support of business activities||Users of the Platform||Yes||Payments processing, tax processing, identity verification, single-sign-on integration|
|Protected classification characteristic under CA or federal law||Age (40 years or older), national origin, citizenship, marital status, sex, veteran or military status.||No||N/A||N/A||N/A||N/A|
|Commercial Information||Contact information and transaction/order history||Yes||To support business transactions||Users of the Platform||Yes||Payments Vendors|
|Biometric information||Physiological, biological, or behavioral characteristics||No||N/A||N/A||N/A||N/A|
|Internet or other similar network activity||IP address, browser type and version, Browsing history, information on a consumer’s interaction with a website, or advertisement||Yes||To allow access to and optimize our Service||User Devices||Yes||Analytics, Advertising|
|Geolocation data||Information that can identify an individual’s precise location||No||N/A||N/A||N/A||N/A|
|Sensory Data||Audio, electronic, visual, thermal, olfactory, or similar information.||No||N/A||N/A||N/A||N/A|
|Professional or employment-related information||Current or past job history or performance evaluations.||No||N/A||N/A||N/A||N/A|
|Non-public education information (per the Family Educational Rights & Privacy Act)||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.||No||N/A||N/A||N/A||N/A|
|Inferences drawn from other personal information||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||To optimize user experience and analyze user trends||Users of the Platform||No||N/A|
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
· To fulfill or meet the reason you provided the information.
· To provide you with information, products, or services and/or to improve the information, products or services provided.
· To provide, support, personalize, and develop our website, products, and services.
· To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, as required by law).
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
We will not collect additional categories of information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
We do not sell your personal information. We may use or disclose the personal information we collect for one of the purposes listed above. We will not collect additional categories.
Sharing Personal Information
We may disclose and have disclosed in the past twelve (12) months personal information to third parties for business purposes as set forth in the above chart in this Notice. In the preceding twelve (12) months, we have not sold personal information.
We may share information with third parties for the purpose of cross-context behavioral advertising. For opt-out options, please see the Your Rights and Choices section below.
· The time required to retain personal data to fulfill business purposes, including providing product/services
· Maintaining corresponding transaction/business records
· Controlling and improving the performance and quality of the Platform
· Handling possible user queries or complaints and locating problems
· Whether the user agrees to a longer retention period
· Whether the law, contracts, and other equivalencies have special requirements for data retention
Your Rights and Choices
The CCPA/CPRA provides California residents with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.
1. Right to Limit Use and Disclosure of Sensitive Personal Information
The only sensitive personal information we affirmatively collect from you is necessary to perform the services or provide the goods or services you requested. We may also periodically receive unsolicited information from you that includes sensitive personal information. If you have questions about how sensitive personal information is collected, please see Exercising Your Rights to contact us.
2. Right to Opt-Out of Personal Information Sharing
You will be opted in by default to the sharing of personal information as defined under the CCPA/CPRA. You can opt out of the sharing of personal information at any time by emailing our Support Team at email@example.com. Please note, we do not track users across devices, so you will have to opt-out from each device where you access our Platform.
3. 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 (see Exercising Your Rights section), 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 disclosed your personal information for a business purpose, a list of the disclosures made identifying the personal information categories that each category of recipient obtained.
4. Correct/Rectify Personal Information
You have the right to request rectification (correction, update, modification) of the personal information we collect about you. After making such a request, we will take commercially reasonable efforts to correct inaccurate personal information within 45 days of receiving the request. In the event an extension is needed, we may take an additional 45 days when reasonably necessary. In this case, we will provide you a notice of extension within the first 45-day period.
5. 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 (see Exercising Your Rights section), we will delete (and direct our service providers and 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 providers/contractors 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, fulfill the terms of a written warranty or product recall in accordance with federal law, or otherwise perform our contract with you.
· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
· Debug products to identify and repair errors that impair existing functionality.
· Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
· Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et seq.)
· 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.
· 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 it.
6. Exercising Your Rights
To exercise the limitation and opt out of data sharing rights please access the links noted above. To ask questions about sensitive personal information or exercise the access, rectification, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at firstname.lastname@example.org
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:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
7. Response Timing and Format
We will try our best to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 will only cover the 12-month period preceding the receipt of the verifiable consumer request’s receipt. 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 usable and should allow you to transmit the information from one entity to another and should allow you to further transmit information if you desire.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or 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.
We will not discriminate against you for exercising your CCPA/CPRA rights. Based solely on the exercise of your CCPA/CPRA rights, we will not:
· Deny you goods or services
· Charge you different prices or rates for goods or services, including through granting discounts or other bene\fits, or imposing penalties
· Provide you a different level or quality of goods or services
· Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services
Changes to Our Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.