Introduction
Welcome to the KYG Trade Attestation Platform and Marketplace™ (the “Platform”). The Platform is provided and controlled by KYG Trade, Inc. (“KYG Trade”, “We” or “Us”). We are committed to protecting and respecting your privacy. This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.
This page informs you of Our policies regarding the collection, use, and disclosure of Personal Data, which KYG Trade obtains from users, when users interact with Our website (www.kygtrade.com), Platform, mobile applications, and related services. This Privacy Policy also explains how your Personal Data is used, shared and protected, what choices you have relating to your Personal Data, and how you can contact KYG Trade. Please read this policy carefully to understand this entire Privacy Policy before submitting information to Us or using Our services. Whenever you submit information to Us, whether online or offline, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.
This policy generally applies to Personal Data that we process for our own business purposes (“KYG Data“), as well as Personal Data that we process on behalf of Our customers through Our Platform and related services (“Platform Data“). This policy does not apply to information that KYG Trade obtains or processes from its employees.
Only persons age 18 or older have permission to access Our Platform. We do not request or knowingly collect Personal Data from individuals under the age of 18. If KYG Trade learns that personally identifiable information of persons under 18 years of age has been collected on the Platform without verified parental consent, KYG Trade will take appropriate steps to delete the information. California residents under 18 years of age may have additional rights regarding the collection and sale of their Personal Data. Please see Our California Privacy Rights Section herein below for more information.
Definitions
Account means a unique account created for you to access Our Service or parts of Our Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to KYG Trade, Inc., 220 Newport Center Dr., Suite 11391, Newport Beach, CA. 92660.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on your computer, mobile Device or any other Device by a website, containing the details of your browsing history on that website among its many uses.
Device means any Device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), 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 Data to another business or a third party for monetary or other valuable consideration.
Sharing, for the purpose of the CCPA, refers to disclosing a Consumer’s Personal Data to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Service refers to the KYG Trade Platform and Marketplace and API.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an Account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself. This includes your device data and how you interact with Our website, including IP address, browser type, and unique device identifier, the pages or content you view and searches on Our website.
You (referred to as either “you” or “your” in this Agreement) means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
1. What Information Do We Collect?
KYG Trade collects the following categories of KYG Data and Platform Data either directly from you, automatically from you when you access Our website and Platform, or from third parties:
a. Information You Choose to Provide
KYG Data: When you interact with our Website, we may collect the following information directly from you.
- Name
- Email address
- Telephone number
Platform Data: For certain activities, such as when you download, access, register with, use, or upload User Content to the Platform, fill in forms in the Platform, or when you enter a contest or promotion sponsored by us, when you report a problem with the Platform, or contact Us directly, you may provide some or all of the following information.
- Name
- Email address
- Employer name
- Job title
- Country of residence and nationality
- Telephone number
- Login and Account information
- User Content on the Platform
Please note that you may also provide information for publication or display on public areas of the Platform (collectively, “User Content“), including but not limited to comments, photographs, images, videos, and audio files, that you choose to upload or broadcast on the Platform. Your User Content is posted, submitted, transmitted, or otherwise made accessible to others at your own risk. Although you may set certain privacy settings for such information, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed or otherwise accessed by unauthorized persons.
b. Automatically Collected Information
KYG Data: When you interact with our Website, advertisements, and related services, we may use technology to automatically collect the following information from you.
- Usage Data. When you access and use the Website, We may automatically collect Usage Data. Usage Data may include information such as: traffic data, location data, logs, the pages of Our Website that you visit, the time and date of your visit, and the time spent on those pages.
- Device Information. We may collect information about the Device you use to access the Website, including the Device’s unique Device identifier, IP address, model of the Device, operating system, browser type, mobile network information, time zone setting, screen resolutions, application and file names and types, and the Device’s telephone number (if applicable).
- Location Information. The Website collects real-time information about the location of your Device, including location information based on your SIM card and/or IP address, and time zone.
Platform Data: When you download, use, or otherwise access the Platform, the Platform may use technology to automatically collect the following information from you.
- Usage Data. When you access and use the Platform, We may automatically collect Usage Data. Usage Data is collected automatically when using the Service. Usage Data may include information such as: traffic data, location data, logs, the pages of Our Platform that you visit, the time and date of your visit, the time spent on those pages, User Content that you generate through and broadcast on the Platform, and other communication data and the resources that you access and use on or through the Platform.
- Device Information. We may collect information about the Device you use to access the Platform and your internet connection, including the Device’s unique Device identifier, IP address, model of the Device, operating system, browser type, mobile network information, time zone setting, screen resolutions, application and file names and types, and the Device’s telephone number (if applicable).
- Location Information. This Platform collects real-time information about the location of your Device, including location information based on your SIM card and/or IP address, and time zone.
- Metadata. The Platform also may access metadata and other information associated with other files stored on the Device you utilize to access the Platform. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your User Content, the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as your Account name, that enables other users to trace back the User Content to your user Account. Additionally, metadata will consist of data that you chose to provide with your User Content, e.g. any hashtags used to mark keywords to the video and captions.
c. Information Collection by and from Third-Party Services
KYG Trade allows you to create an Account on Our Platform and log in through the following Third-party Social Media Services:
- Apple
- Microsoft
If you decide to register through or otherwise grant Us access to a Third-Party Social Media Service, KYG Trade may collect Personal Data that is already associated with your Third-Party Social Media Service’s account, such as your name, your email address, your activities or your contact list associated with that account.
You may also have the option of sharing additional information with KYG Trade through your Third-Party Social Media Services account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving KYG Trade permission to use, share, and store it in a manner consistent with this Privacy Policy.
Additionally, when you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your Device. These third parties may include, but are not limited to:
- Advertisers, ad networks, and ad servers.
- Analytics companies.
- Social Networks.
- Your mobile Device manufacturer.
- Your mobile service provider
These third parties may use tracking technologies to collect information about you when you use this Website and/or related content. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites, applications, and other online services websites. These third parties may use this information to provide you with interest-based advertising or other targeted content. For information about how you can opt-out of receiving targeted advertising from many providers, such information is provided herein below.
2. Tracking Technologies and Cookies
KYG Trade may use cookies and other similar technologies (e.g., web beacons, tags, scripts, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Website and Platform, track the activity on the Website and Platform, store certain information, enhance your experience using the Website and Platform, improve the Website and Platform, and provide you with targeted advertising on the Platform and elsewhere across your different Devices.
Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or Device. Cookies are small files which, when placed on your Device, enable the Website and Platform to provide certain features and functionality. It may be possible to refuse to accept all cookies by activating the appropriate setting on your browser or Device or to indicate when cookies are being sent. However, if you select this setting, you may be unable to access certain parts of Our Website or Platform. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile Device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both session and persistent Cookies for the purposes set out below:
a. Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.
b. Analytics Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website and hep Us measure visitors’ usage and behavior on our Website.
c. Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website.
3. Use of Your Personal Data
KYG Trade may use the information detailed herein, that we collect about you or that you provide to us, including any Personal Data, for the following purposes:
- To provide, maintain, and improve Our Platform, Website, and Content, including monitoring the usage of Our Service.
- To detect, prevent, mitigate, and investigate technical issues.
- To detect, prevent, mitigate, and investigate abuse, fraud, security breaches, and potentially prohibited or illegal activities on the Platform.
- To comply with legal, regulatory, or contractual requirements.
- To enforce Our terms, conditions, and policies.
- To ensure that you are old enough to use the Website and Platform (as required by law).
- To manage your registration as a user of the Service including expiration and renewal notices. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
- For the performance of Our contract with you.
- To fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.
- To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are like those that you have already purchased or enquired about unless you have opted not to receive such information.
- To manage your requests.
- To allow you to participate in interactive features of the Platform and Website.
- To allow you to post information and other User Content on the Platform.
- To support the social functions of the Platform, including to permit you and other users to connect with each other through the Platform and for you and other users to share, download, and otherwise interact with User Content posted through the Platform.
- To customize the content, you see when you use the Platform and Website.
- To deliver targeted marketing, service updates, and promotional offers based on your communication preferences.
- To understand how you use the Website and Platform, including across your Devices.
- For any other purposes disclosed to you at the time We collect your information or pursuant to your consent.
KYG Trade may further use the information We collect to display advertisements to Our advertisers’ target audiences. We do not disclose your Personal Data for these purposes without your consent.
KYG Trade may make full use of all information that is de-identified or otherwise not in personally identifiable form. We may also make full use of all User Content you submit to us, in accordance with Our Terms of Use.
4. Disclosure of Your Personal Data
We are committed to maintaining your trust, and while KYG Trade does not sell Personal Data to third parties, we want you to understand when and with whom we may share the information We collect for business purposes.
We may disclose personally identifiable information that we collect, or you provide in accordance with the Privacy Policy and Our Terms of Use, including in the following instances:
- To Our parent, subsidiary, or another affiliate of Our corporate group. We may share your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- To Service Providers to support Our business and operations (e.g., delivery services, financial institutions, fulfillment services, technical support, advertising, public relations, media and marketing services, sweepstakes, promotions, campaigns and contest-related services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services and event-related services such as online and offline data capture), and who are to keep Personal Data confidential and use it only for the purposes for which We disclose it to them.
- To a buyer or other successor in the event of a sale, financing, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of KYG Trade’s assets, or other transfer of Our brand or company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by KYG Trade about Our Platform users is among the assets transferred.
- With your consent. We may share information for other purposes pursuant to your consent or with your further direction. If you choose to engage in public activities on the Platform, or with other users, you should be aware that any information you share may be viewed, read, collected, used by other users, and may be distributed outside the Platform. you should use caution in disclosing Personal Data while engaging in public areas and with other users. We are not responsible for the information you choose to submit. If you interact with other users or register through a Third-Party Social Media Service, your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
- For legal reasons to comply with any court order, law, subpoena, law enforcement request, legal claims, or legal process, including to respond to any government or regulatory request, and to protect and defend the rights, interests, safety, and security of KYG Trade, the Platform, Our affiliates, users, or the public. KYG Trade may also share your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law.
- To identify, contact, or bring legal action against to someone who may be causing injury to or interfering with KYG Trade’s or other’s rights or property, including in connection with disciplinary actions/investigations regarding your use of the Platform or Service.
5. Sharing and Selling Your Personal Data
Company Shares certain Personal Data that we collect for our own commercial purposes with trusted third-party marketing partners to deliver personalized advertisements tailored to your interests, helping you discover products and services that align with your preferences. This information may include device identifiers, IP address, browser type, website usage and referring URLs, purchase activity, and geolocation information.
Please note that we do not Share information that we collect or process on behalf of our customers through our Platform.
Company has not Sold Personal Data in the preceding twelve months and does not Sell Personal Data pertaining to minors under the age of 16.
6. Cross-Border Transfer of Your Personal Data
The recipients of your Personal Data may be located in the United States or other jurisdictions that might not provide a level of protection equivalent to the laws in your jurisdiction. Your Personal Data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that We transfer Personal Data to the United States and process it there. When we do so, we implement a transfer mechanism to help ensure the security of your Personal Data, including EU standard contractual clauses.
KYG Trade will take all steps reasonably necessary to ensure that no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place.
Your Rights and Choices about Collection, Use and Disclosure of Your Personal Information
1. Data Collection
We strive to provide you with choices regarding the Personal Data you provide to us. This section describes mechanisms We provide for you to control certain uses and disclosures of your information.
a. Tracking Technologies. you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You may choose whether or not to allow the Website or Platform to collect information through other tracking technologies by Opting Out. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile applications function, you may need to take different steps to disable Cookies used for targeted advertising in a browser and to disable targeted advertising for a mobile application, which you may control through your Device settings or mobile application permissions. In addition, your choice to disable cookies is specific to the particular browser or Device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or Device.
Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
b. Location Information. You can choose whether or not to allow the Website or Platform to collect and use real-time information about your Device’s location through the Device’s privacy settings. If you block the use of location information, some parts of the Website or Platform may become inaccessible or not function properly.
c. Targeted Advertising: If you wish to opt out of the use of your Personal Data for targeted advertising or promotional purposes, you may do so by following the instructions below:
o Website: You can opt out of receiving ads that are personalized by following Our instructions presented on the Service. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
o Mobile Devices: your mobile Device may give you the ability to opt out of the use of information about the applications you use in order to serve you ads that are targeted to your interests.
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
- You can also stop the collection of location information from your mobile Device by changing the preferences on your mobile Device.
o Emails: You may opt-out of receiving any, or all, communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We do not control third parties’ use of your information to serve targeted advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
2. Data Security, Retention, and Legal Bases for Processing
a. Information Security: The security of your data is important to KYG Trade, and We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. But remember that no website, mobile application, database or system, or method of transmission over the Internet, or method of electronic storage is 100% secure or “hacker proof.” The safety and security of your information also depends on you. While We use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You can help keep your data safe by taking reasonable steps to protect your Personal Data against unauthorized disclosure or misuse. Personal Data We are not responsible for the circumvention of any privacy settings or security measures We provide.
Where We have given you (or where you have chosen) a password for access to certain parts of Our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.
b. Retention of Your Personal Data: We retain your Personal Data for as long as necessary to fulfill the purposes described in this policy, unless otherwise required by law. To determine the appropriate retention period for Personal Data, we consider applicable laws, the volume and nature of the Personal Data, its purpose, and the potential risk of harm from its unauthorized use or disclosure.
c. Legal Bases for Processing Personal Data: We may process Personal Data under the following conditions and will gladly clarify the specific legal basis that applies to such processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
- Consent: You have given your consent for processing Personal Data for one or more specific purposes. Where We have obtained your consent for the processing of your Personal Data, you have the right to withdraw your consent at any time. If you have a request regarding your Personal Data, please contact us.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary to protect your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
3. Accessing, Correcting, and Managing Your Personal Data
Managing Your Personal Data, Content, And Notifications: You may contact us, as provided below, to learn about how to access, review, correct, update, transfer, or delete the information about you in Our records, depending on where you live. We may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. You may have the right to request:
- access to your Personal Data;
- an electronic copy of your Personal Data (portability);
- correction of your Personal Data if it is incomplete or inaccurate; or
- deletion or restriction of your Personal Data in certain circumstances provided by applicable law;
- that your Personal Data is not shared for targeted advertising purposes.
- transfer to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you.
You may exercise your above rights by contacting KYG Trade. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will respond to your within 30 calendar days.
If you have registered for an account you may access, review, and update certain Personal Data that you have provided to Us by logging into your account and using available features and functionalities.
You may also send Us an email at Privacy@kygtrade.com to request access to, correct, or delete any Personal Data We have collected about you or that you have provided to us. We will respond to your request consistent with applicable law and subject to proper verification. We do not discriminate based on the exercise of any privacy rights that you might have exercised. Please note that We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if We believe the change would violate any law or legal requirement or cause the information to be incorrect.
4. California’s Shine the Light Statute (Civil Code Section § 1798.83) permits users of Our Platform that are California residents with an established business relationship with Us to request certain information regarding Our disclosure of Personal Data to third parties for their direct marketing purposes.
As such, if you are a California resident, once a calendar year, you may be entitled to obtain information about the Personal Data that We shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which We shared customer information for the immediately prior calendar year. To request a notice, please submit your request to Privacy@kygtrade.com. KYG Trade will respond to such written requests within a reasonable period, but not to exceed 180 days from the date received. Please note that We are required to respond to each customer only once per calendar year.
b. California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the User Content you want to be removed and information reasonably sufficient to permit Us to locate that User Content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and We may not be able to respond if you do not provide adequate information. Please note that your request does not ensure the complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
To request the removal of such data, and if you are a California resident, you can contact Us using the contact information provided below, and include the email address associated with your account. Be aware that your request does not guarantee the complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, you can contact us:
By email: privacy@kygtrade.com
By mail: 220 Newport Center Dr., Suite 11391, Newport Beach, CA 92660
California Department of Consumer Affairs – Complaint Assistance Unit
By phone: (800) 952-5210
California Addendum
Personal Information We Collect
In the last twelve months, we have collected the following categories of Personal Data from Consumers:
| Category | Examples | Collected | Disclosed | Shared |
| Identifiers | 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. | YES | NO | YES |
| Personal information categories listed in the California Customer Records statute. | 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, 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. | NO | NO | NO |
| 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). | NO | NO | NO |
| Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO | NO | NO |
| 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 | NO | NO |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES | YES | YES |
| Geolocation data. | Physical location or movements. | YES | YES | YES |
| Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO | NO |
| Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO | NO |
| Non-public education information (per the Family Educational Rights and Privacy Act). | 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 | NO | NO |
| Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | NO | NO |
| Sensitive Personal Data. | (1) Social Security number, driver’s license number, state identification number, passport number; (2) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (3) precise geolocation information; (4) racial or ethnic origin, religious, or philosophical believes, or union membership; (5) contents of mail, email, and text messages unless the business is the intended recipient of the communication; (6) genetic data; (7) biometric data for the purposes of uniquely identifying a consumer; (8) health information; (9) sex life or sexual orientation information. | NO | NO | NO |
We obtain this information from the various categories of sources:
- Directly from you. For example, when you provide your name and contact information to create an account.
- Indirectly from you. For example, from observing your interactions on our website.