Privacy Policy – Additional Information for California Residents

Salas O’Brien Privacy Notice – Additional Information for California Residents

Effective Date: August 19, 2024

This Additional Information for California Residents (“California Privacy Notice”) is designed to meet Salas O’Brien, Inc.’s and its affiliates’ and subsidiaries’ (“Company,” “we,” “us” or “our”) obligations under applicable California laws, including but not limited to the California Privacy Rights Act of 2020 (“CCPA”) and California’s “Shine the Light” law, and supplements our Privacy Policy. In the event of a conflict between our Privacy Policy and this California Privacy Notice, this California Privacy Notice will prevail as to California residents unless stated otherwise.

The CCPA requires businesses subject to the CCPA to make certain disclosures regarding the collection, use and disclosure of personal information and provides California residents with specific rights regarding their personal information. This California Privacy Notice provides those disclosures and describes rights available to California residents, along with how to exercise those rights with respect to personal information held by us.

 

Collection, Use and Disclosure of Personal Information

We have collected the following categories of personal information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this U.S. Supplement:

 

Categories of Personal Information We Collect About California Consumers

• Identifiers such as name, telephone number, postal address, organization/company name, unique personal identifier, online identifier, IP address, email address, or other similar identifiers
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement
• Geolocation data, consisting of approximate location inferred from IP address

 

Categories of Recipients to Whom Personal Data is Disclosed

We may disclose the categories of personal information identified above with the following categories of recipients:

• With Third Party Service Providers Performing Services on Our Behalf. We may share your personal information with our service providers to perform the functions for which we engage them.
• With our Affiliates and Subsidiaries. We may share your information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures or companies under common control) for our internal business purposes.
• With Law Enforcement, Courts and Other Third Parties for Legal Purposes. We may share information as needed to enforce our rights, respond to a subpoena, regulation, legal process, governmental request or other legal or regulatory process.
• To Successors in Interest. We may transfer or assign information that we have collected in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We may disclose the following categories of personal information to website and data analytics providers. This disclosure may be considered a “sale” of personal information under the CCPA.

• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement
• Geolocation data, consisting of approximate location inferred from IP address

 

Categories of Sources from which We Collect Personal Information

We collect the personal information described above from or through the following categories of sources:

• From you directly and indirectly, including when you access/visit the Site, purchase our products, use our products, request a demo of our products or sign up for a free trial, create an account with us, sign up to receive our newsletters and/or marketing communications, sign up for our webinars/events/forums or contact us, or provide us with information at trade shows and other in-person events; and
• From third parties, including from individuals making a referral and from our service providers who provide analytics services to help us understand the activity on the Site.

 

Business or Commercial Purposes for Collecting and Disclosing Personal Information

We collect and disclose the personal information described above for a variety of business purposes including:

• to provide the Site to you and to improve the Site;
• to provide, operate, improve, and personalize the services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• to perform a contract with you or the organization with which you are affiliated;
  to provide you with information about products and services that we may provide that we think may be of interest to you;
• to provide you with updates about our services and with transactional information;
  for customer service and/or support, security (including for authentication purposes), to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• for analytics purposes;
• to communicate with you;
• to comply with applicable laws or respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process;
• to enforce our rights, protect our property or protect the rights, property or safety of others; and
• as needed to support external auditing, compliance and corporate governance functions.

We will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

 

California Residents’ Personal Information Rights

The CCPA provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights.

 

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

1. The categories of personal information we have collected about you.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting, selling or sharing personal information.
   The categories of third parties with whom we disclose personal information.
4. The specific pieces of personal information we have collected about you.

 

You may also request that we disclose to you:

1. The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
2. The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

 

Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

 

Right to Opt-Out of Sale or Sharing of Personal Information

We do not sell your personal information for monetary consideration. However, if you visit our Site we may use third-party cookies for website analytics and digital advertising purposes. The collection of data through certain third-party cookies for our analytics and digital advertising purposes may be considered a “sale” and “sharing” of personal information under the CCPA. To opt-out of having your information sold and shared with third-party website analytics providers or third party digital services providers for this purpose, visit our “Do Not Sell or Share My Personal Information” cookie consent management tool.

 

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

 

Right to Limit Use and Disclosure of Sensitive Personal Information
We do not collect your sensitive personal information.

 

No Discrimination
You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request
To exercise the rights described above, you must submit a verifiable request to us. You can submit a request by calling us at 877.725.2755 or by submitting a request online at salasobrien.com/contact and selecting “Data Rights Request.” We will then contact you about your request. To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

 

Personal Information of Minors
We do not have actual knowledge that we sell or share personal information about minors under the age of 16.

 

California “Shine the Light” Law
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please use our “Contact us” form at https://salasobrien.com/contact/ and select “Data Rights Request.” We will then contact you about your request.