Supplemental Privacy Policy for California Residents

Last updated: 8.21.2024

We provide the following information to California residents pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This information supplements our general Privacy Policy. For a description of all of our data collection, use and disclosure practices, please read our Privacy Policy in its entirety. Terms that are capitalized but not defined below have the meanings set forth in our Privacy Policy.

Categories of Personal Information

Below, we describe the categories of Personal Information (as defined in the CCPA), that we have collected within the preceding 12 months and may collect on a going-forward basis:

  • Identifiers
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, address, email address)
  • Characteristics of protected classifications under California or federal law
  • Commercial information (e.g., transaction data)
  • Internet or other similar network activity
  • Geolocation data (e.g., general location derived from an IP address)
  • Professional or employment-related information
  • Education information
  • Inferences drawn from the preceding categories of Personal Information

Within these categories of Personal Information, we may also collect the following categories of Sensitive Personal Information (as defined in the CCPA): Account log-in, financial account, debit card, or credit card number, in combination with any required security or access codes, password, or credentials allowing access to the account.

Categories of Recipients of Personal Information

For each category of Personal Information (including Sensitive Personal Information) listed above, we disclose this information as described in the ‘How We Disclose Your Information’ section of our Privacy Policy. In addition, we may disclose Identifiers and Internet or other similar network activity to advertising providers that tailor online ads to your interests based on information they collect about your online activity (known as interest-based advertising).

Sources of Personal Information

We obtain the categories of Personal Information listed above directly from you or from devices on which you use our Services, as well as from the following categories of sources: publicly-available databases, third-party business partners, social media sites, and other third-party sources, and as described in our ‘Information We Collect About You’ section of the Privacy Policy.

Purposes for Which We Use Personal Information

We use Personal Information for a variety of business and commercial purposes, as described in the ‘How We Use Your Information’ section of our Privacy Policy.

Retention Period Criteria

Sublynk retains the Personal Information described above for as long as you use our Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in our Privacy Policy (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.

CCPA Rights and Requests

You may make the following types of requests under the CCPA with respect to Personal Information that we process on our own behalf. Note, if you wish to make a CCPA request with respect to Personal Information submitted through or otherwise made available to the Platform Services, please direct your request to the relevant Customer directly, as that data is governed by the terms of our agreement with our Customer.

Requests to Know, Correct, and Delete 

You may request:

  • Access to a copy of the specific pieces of Personal Information that we have collected about you
  • Correction of Personal Information that we maintain about you, if it is inaccurate
  • Deletion of Personal Information, subject to certain exceptions

You can submit a request online by emailing us at legal@sublynk.com. We will respond to your request consistent with the CCPA, and subject to any exceptions that may apply under the CCPA. We may need to request additional Personal Information from you, such as email address, state of residency, or mailing address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.

Requests to Opt-Out of Sale or Sharing

You also may opt out of the “sale” or “sharing” of your Personal Information, as “sale” and “sharing” are defined under CCPA.

We do not sell Personal Information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “sale” and “sharing” under the CCPA may include the disclosure of your information to certain types of advertising and marketing partners, we provide California residents with the right to opt-out of any such sale or sharing of their Personal Information. As noted above, we may disclose or make available Identifiers or Internet or other similar activity to advertising partners. We allow you to opt out of such disclosures, as they may constitute “sale” or “sharing” as defined under the CCPA. We do not knowingly “sell” or “share” the Personal Information of individuals under 16 years of age.

You may opt-out of the Sale or Sharing of Personal Information for purposes of online analytics and advertising by emailing us at legal@sublynk.com. We also recognize opt-out preference signals as required by the CCPA.

Authorized Agents

To make a request as an authorized agent on behalf of a California resident, you may use the submission method noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent.

If you are making a Request to Know, Correct, or Delete on behalf of a California resident and have not provided us with a qualifying power of attorney from the resident, we may also require the resident to verify their own identity directly with us; or directly confirm with us that they provided you permission to submit the request.

Nondiscrimination

You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights.

California "Shine the Light" Disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. For more information about our compliance under the Shine the Light law please contact us at legal@sublynk.com.

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