CALIFORNIA PRIVACY POLICY

Last Revised on July 29th, 2020.

This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in Callspree’s primary privacy policy. Callspree (“we,” “us,” or “our”) has adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy. This Privacy Notice applies solely to residents of the State of California (“Users”).

This California Privacy Policy is parallel in scope to our privacy policy.

DEFINITIONS SPECIFIC TO THIS POLICY

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to Callspree’s privacy policy, including the following terms:

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information obtained from government records; de-identified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

“Sale” or “sell” means 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.

“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

THE PERSONAL INFORMATION WE COLLECT AND DISCLOSE

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). We do not sell the personal information of minors under 16 years old without affirmative authorization. In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following the submission of your request if this is the case.

• If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom we have shared that Personal Information; and (4) the business purpose for collecting that Personal Information, click here. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify.
• If you would like to request the specific pieces of Personal Information we collected about you, click here. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify.
• If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose, click here. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify.

VERIFICATION PROCESS

Upon receipt of the personal information request from the consumer, Callspree will attempt to identify the consumer in one of three ways before initiating the request to know, request to opt-out, or request to delete procedures. Consumers that submit a request to know or request to opt-out, two data points are used to identify the consumer before the process is initiated. For consumers that submit a request to delete, three data points are used to identify the consumer before the process is initiated.

Non-Discrimination

We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

Deletion of Your Personal Information

You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following the submission of your request if this is the case.

If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, click here. The link will take you to an interactive web form that you can complete and submit to make a request for deletion that we will then verify.

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf.

• Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
• You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
• We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
• Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.

Personal Information of Minors – Opting In

We do not sell the Personal Information of minors who are at least 13 years old and less than 16 years old unless those individuals have opted into the sale of their Personal Information. To opt-in, such a minor must first clearly request to opt-in via the link below, after which the minor will be required to separately confirm that election. As part of that confirmation process, the minor will be informed that he or she has the right to opt-out at a later date and what the process is for doing so.

If you are 13, 14, or 15 years old and would like to opt into the sale of your Personal Information, click here.

We do not sell the Personal Information of minors who are under 13 years old unless a parent or guardian of that minor affirmatively authorizes the sale of that Personal Information. We verify that the individual making such authorization is the minor’s parent or guardian by providing a consent form to be signed by the parent or guardian under penalty of perjury and returned to the business by postal mail, facsimile, or electronic scan. As part of that verification process, the parent or guardian will be informed that he or she may opt-out on behalf of the minor at a later date and what the process is for doing so.

If you are the parent or guardian of a minor under 13 years old and would like to opt into the sale of the minor’s Personal Information, click here.

Right to Opt-Out

You have the right to request that we do not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.

• If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, click here. The link will take you to an interactive web form that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
• You may also submit a request to opt-out by sending an email with the required information to the following email address info@callspree.com.
• If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.

You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, click here. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Additional Information

If you would like additional information regarding our California Privacy Policy, please email us at info@callspree.com.

Changes to Our California Privacy Policy

Callspree reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.