Last Updated: September 1, 2021
Where noted below, 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.
We have collected the following categories of personal information from consumers within the last twelve (12) months:
Examples Corresponding to Category
|Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.|
|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 identification card number, insurance policy number, education, employment or employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|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).|
|Commercial information.||Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|Geolocation data.||Physical location or movements.|
|Sensory data.||Audio, electronic, visual, or similar information.|
|Professional or employment-related information.||Current or past job history or professional activities.|
|Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, behavior, attitudes, abilities, and aptitudes.|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you through person-to-person communication. For example, from electronic communications with our marketing and sales personnel.
- Directly from you through our website. For example, from your submitting information through online forms or from your interacting with our website’s chat bot.
- Indirectly from you. For example, through observing your actions on our website.
- From third-party professional references that are internal or external to your company.
- From third-party advertising, performance marketing, contact database platforms and event-hosting companies, as well as from social media.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To satisfy the reason you provided information. For example, if you share your contact information to inquire about our services, we will use that personal information to respond to your inquiry and help you evaluate our services.
- If you provide your personal information to purchase a service, we will use that information to process your requests, transactions and payments, to prevent transactional fraud, and to facilitate service.
- To create, maintain, customize, and secure your account with us.
- To protect against malicious, deceptive, fraudulent, or illegal activity.
- To monitor and improve our responses and services, as well as to support and develop our Website and its content.
- To meet performance obligations under contracts with customers, including those related to billing and collections.
- To deliver marketing and sales content as well as service offerings relevant to you and your interests, including email alerts and materials delivered in hard copy.
- For testing, research, analysis, and improvement of products and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As needed to protect the rights, property or safety of CYBELANGEL, our customers or others.
- For internal finance and operational functions, including audits.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization or other sale or transfer of some or all of our interests or assets, in which personal information held by us about our consumers may be transferred.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosures of Personal Information for a Business Purpose
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 into 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.
In the preceding twelve (12) months, CYBELANGEL has disclosed the following categories of personal information for a business purpose:
- California Customer Records personal information categories.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Sensory data.
- Professional or employment-related information.
- Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers, including those offering marketing and event management software, chat bot technology, website hosting, application usage analytics, and digital advertising solutions. This includes our partner NextRoll, whose statement of rights for consumers is available here: California Residents section of NextRoll’s Service Privacy Notice.
- Third-party individuals or businesses, when you may have agreed to act as a reference or referral.
In the preceding twelve (12) months, CYBELANGEL has not sold personal information.
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 12 months. Once we receive and confirm your verifiable consumer request, 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 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.
- If we disclosed your personal information for a business purpose, a list of the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information.
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, 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 providers 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 otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
- Debug products to identify and repair errors that impair existing intended 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.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1 (888) 212-0462.
- Emailing us at [email protected].
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 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 make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional 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 we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly 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 any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, 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 or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which CybelAngel collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1 (888) 212-0462
Email: [email protected]