CCPA

Privacy Notice for California Residents

 

Effective Date: January 1, 2020

 

This Privacy Notice for California Residents (the "Notice") supplements the information contained in the Privacy Policy, located at https://newnew.co/privacy, (the "Privacy Policy") for the Website of Suprize Inc. (the "Company") and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. All other defined terms, not herein defined, shall have the same meaning as defined in the Privacy Policy.

 

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

 

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, household, or device ("personal information").  Personal information does not include:

·   Publicly available information from government records.

·   Deidentified or aggregated consumer information.

·   Information excluded from the CCPA's scope, like:

·   health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); or

·   personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA) or the Gramm-Leach-Bliley Act (GLBA).

 

In particular, we have collected the following categories of personal information from our customers within the last twelve (12) months:



Category

A. Identifiers.

Examples

A real name,  alias, postal address, unique personal identifier, online identifier,  Internet Protocol address, email address, account name, Social Security  number, driver's license number, passport number, or other similar  identifiers.

Collected

YES

B. Personal  information categories listed in the California Customer Records statute  (Cal. Civ. Code § 1798.80(e)).

A name, signature,Social Security number, physical characteristics or description, address,telephone number, passport number, driver's license or state identificationcard number, insurance policy number, education, employment, employmenthistory, bank account number, credit card number, debit card number, or anyother financial information, medical information, or health insuranceinformation.Somepersonal information included in this category may overlap with othercategories.

YES

C. Protected  classification characteristics under California or federal law.

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 (including familial genetic  information).

YES

D. Commercial  information.

Records of  personal property, products or services purchased, obtained, or considered,  or other purchasing or consuming histories or tendencies.

NO

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, and 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,  application, or advertisement.

YES

G. Geolocation  data.

Physical location  or movements.

YES

H. Sensory data.

Audio,  electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related  information.

Current or past  job history or performance evaluations.

NO

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.

NO

K. Inferences  drawn from other personal information.

Profile  reflecting a person's preferences, characteristics, psychological trends,  predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

The Company obtains the categories of personal information listed above from the following categories of sources:

·      When you establish an account with us.

·      When you visit or use our mobile app.

·      When you participate in our surveys, contests, promotions, content submissions, and        chats.

·      When you report a problem with our app.

·      Records and copies of your correspondence (including e-mail addresses), if you contact        us, including email and chat transcripts.

·      When you communicate with any of our departments, such as customer service.

·      When you use certain payment methods.

·      When you electronically sign contracts with us.

·      Third-party advertising and marketing companies.

·      Your devices may provide us with information.

·      Service providers, who help us maintain and provide the app.

·      Service providers, who help us provide advertising and track customer interactions on our        App and through advertisements.

 

 

Use of Personal Information:

 

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

 

·       To provide and maintain our app, products, services and content to you.

·       To allow you to establish an account with us.

·       To promote our app and content.

·       To provide you with information, products or services and to communicate with you about         information that you request.

·       To notify you about changes to our app, or any products or services we offer or provide         though it.

·       To allow you to participate in our contests and games.

·       To analyze trends and conduct research about improving our products and services.

·       To improve our product strategy and user experience design.

·       To answer your questions.

·       To provide support and respond to your questions.

·       To improve our app, products and/or services.

·       To learn about our users' needs.

·       To filter content and enforce our terms.

·       To contact usersfor research, informational, and marketing purposes, including         customizing our product recommendations and promotions to you based upon your         information.

·       To track traffic patterns and app usage.

·       To provide customer support.

·       To provide you with certain functionality (such as push notifications).

·       When you have us send certain content to other individuals using the app.

·       To send you promotional, advertising and other marketing materials or communications         from us or our agents, and provide you with more relevant advertisements.

·       To identify or aggregate your information.

·       To send you newsletters, marketing emails and/or to inform you about our products,         services and promotions.

·       To protect ourselves and our users.

·       To enforce and/or defend our rights, and if and to the extent necessary for any resulting         legal dispute.

·       To respond to law enforcement requests and as required by applicable law, court order, or         governmental regulations.

·       To generate personas, personal preferences, market trends from algorithmic         processing/analysis.

·       To evaluate or conduct a merger, divestiture, stock sale, restructuring,         reorganization, dissolution, or other sale or transfer of some or all of our assets, whether         asa going concern or as part of bankruptcy, liquidation, or similar proceeding, in which         case personal information held by us about our customers is among theassets         transferred.

·       As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

We will not collectadditional categories of personal information or use the personal informationwe collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

SharingPersonal 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 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 share your personal information with the following categories of third parties:

·       Service providers(such as IT services and website hosting companies).

·       Credit card companies.

·       Analytics Companies.

·       Electronic Signature Companies.

·       Advertising and Marketing Companies.

·       Shippers.

 

Disclosures of Personal Information for a Business Purpose:  In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

Category A:     Identifiers.

CategoryB.     California Customer Records personal information categories.

Category F:     Internet or other similar network activity.

Category G:    Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

·      Service providers (such as IT services and website hosting companies).

·      Credit card companies.

·      Analytics Companies.

·      Electronic Signature Companies.

·      Advertising and Marketing Companies.

·      Shippers.

 

Sales of Personal Information:

Cal. Civ. Code § 1798.140(t)(1) defines "sell" as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

 

In the preceding twelve (12) months, the Company has "sold" the following categories of personal information to third parties:

Category A:     Identifiers.

Category F:     Internet or other similar network activity.

Category G:    Geolocation data.

 

We"sell" (see definition above) your personal information to the following categories of third parties:

§  Advertising and Marketing Companies.

§  Analytics Companies.

 

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 twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability,and Deletion Rights, 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 listsdisclosing:

·       sales, identifying the personal information categories that each category of recipient purchased; and

·       disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

We do not provide these access and data portability rights for B2B personal information.

 

DeletionRequest 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 Access,Data Portability, and Deletion Rights), 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 information is necessary for us or our service provider(s) to:

1.     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 conducted in accordance with federal law, or otherwise perform our contract with you.

2.     Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.     Debug products to identify and repair errors that impair existing intended functionality.

4.     Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for bylaw.

5.     Comply with the California Electronic Communications PrivacyAct (Cal. Penal Code § 1546 et. seq.).

6.     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.

7.     Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8.     Comply with a legal obligation.

9.     Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

We do not provide these deletion rights for B2B personal information.


ExercisingAccess, Data Portability, and Deletion Rights: To exercise the access, data portability, and deletionrights described above, please submit a verifiable consumer request to us byeither:

·       Calling us at 855-563-9639

·       Emailing us at legal@newnew.co

 

Only you, orsomeone legally authorized to act on your behalf, may make a verifiableconsumer request related to your personal information.  

 

You may only make averifiable consumer request for access or data portability twice within a12-month period. The verifiable consumer request must:

·       Provide sufficient informationthat allows us to reasonably verify you are the person about whom we collectedpersonal information or an authorized representative.

·       Describe yourrequest with sufficient detail that allows us to properly understand, evaluate,and respond to it.

 

We cannot respondto your request or provide you with personal information if we cannot verifyyour identity or authority to make the request and confirm the personalinformation relates to you.

 

Making a verifiableconsumer request does not require you to create an account with us.

 

We will only usepersonal information provided in a verifiable consumer request to verify therequestor's identity or authority to make the request.

 

ResponseTiming and Format:  Weendeavor to respond to a verifiable consumer request within forty-five (45)days of its receipt. If we require more time (up to forty-five (45) days), wewill inform you of the reason and extension period in writing.

 

We will deliver ourwritten response by mail or electronically, at your option.

 

Any disclosures weprovide will only cover the 12-month period preceding the verifiable consumerrequest's receipt. The response we provide will also explain the reasons we cannotcomply with a request, if applicable. For data portability requests, we willselect a format to provide your personal information that is readily useableand should allow you to transmit the information from one entity to anotherentity without hindrance.

 

We do not charge afee to process or respond to your verifiable consumer request unless it isexcessive, repetitive, or manifestly unfounded. If we determine that therequest warrants a fee, we will tell you why we made that decision and provideyou with a cost estimate before completing your request.

 

FinancialIncentives: Fromtime to time, we may offer various financial incentives. The terms of thefinancial incentive will be presented to you at the time you signup for theoffer.

 

Non-Discrimination:  Wewill not discriminate against you for exercising any of your CCPA rights.Unless permitted by the CCPA, we will not:

·       Deny you goods orservices.

·       Charge youdifferent prices or rates for goods or services, including through granting discountsor other benefits, or imposing penalties.

·       Provide you adifferent level or quality of goods or services.

·       Suggest that youmay receive a different price or rate for goods or services or a differentlevel or quality of goods or services.

 

Changes to This Notice

 

We reserve theright to amend this Notice at our discretion and at any time. When we makechanges to this Notice, we will post the updated Notice on our Website andupdate the Notice's effective date. Yourcontinued use of our Website following the posting of changes constitutes youracceptance of such changes.

 

Contact Information

 

If you have any questionsor comments about this Notice, the ways in which the Company collects and usesyour information described herein, your choices and rights regarding such use,or wish to exercise your rights under California law, please do not hesitate tocontact us at:

·       Phone: 855-563-9639

·       Email: legal@newnew.co