Effective date: December 2022
Last updated: April 2024
This California Consumer Privacy Notice (“Notice”) supplements i360’s (“i360”) Privacy Policy and applies solely to the personal information collected online and offline of California consumers (excluding i360 employees, applicants, contractors, and other personnel).
This Notice is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), and its implementing regulations (collectively, the “CCPA”), and certain terms used herein have the meaning given to them in the CCPA. Nothing in this Notice is intended to contradict or limit the applicability of the information provided in our Privacy Policy.
1. Notice of Collection and Use of Personal Information
i360 collects information from government and other sources. In doing so, we may collect (and may have collected during the 12-month period prior to the last updated date of this California Consumer Privacy Notice) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology, telephone number, and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: physical characteristics or description, education, income level and other financial information, and medical-related information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, marital status, medical-related information, ancestry, and military and veteran status
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements
- Geolocation Data: Location data based on IP address
- Sensory Information: audio, electronic, and similar information when you call i360 and leave a voicemail, or record such information on an i360 software application
- Employment Information: professional or employment-related information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, or attitudes
- We may use (and may have used during the 12-month period prior to the last updated date of this California Consumer Privacy Notice) your personal information for the purposes described in our Privacy Policy. In addition, we may use such categories of personal information for certain business purposes specified under the CCPA, including as described below:
- Performing services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services
- Marketing: Providing advertising and marketing services
- Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short Term Use: Short-term, transient use such as non-personalized advertising shown as part of your current interaction with us
- Security Purposes: Helping to ensure security and integrity
- Debugging: Debugging to identify and repair errors that impair existing intended functionality
- Internal R&D: Undertaking internal research for technological development and demonstration
- Safety: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
We also may collect additional information or use the information listed above in other ways for which we provide specific notice at the time of collection.
To the extent we process de-identified information, we will maintain and use the information in de-identified form and will not attempt to re-identify the information unless permitted by applicable law.
2. Retention of Personal Information
We retain personal information as described in the “How Long is Personal Information Retained” section of our Privacy Policy.
3. Sources of Personal Information
During the 12-month period prior to the last updated date of this California Consumer Privacy Notice, we may have obtained personal information about you from various sources, including as described below:
- Directly from you, such as when you connect to us via social media, send us questions, requests, or comments, elect to receive business alerts, newsletters, and other communications, or when you provide information about an incident or allegation
- From your devices, such as when you visit our website or use our mobile applications
- Our affiliates
- Social networking services
- Online advertising companies
- Consumer data vendors and other data suppliers with whom we have contractual agreements
- Public databases
- i360/system generated data
4. Disclosure of Personal Information
During the 12-month period prior to the last updated date of this California Consumer Privacy Notice, we may have disclosed your personal information with certain categories of third parties, including as described in our Privacy Policy and below, including for the business purposes described above.
Categories of Third Parties
Categories of Personal Information
Our affiliates
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Third-party vendors who provide services on our behalf
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Marketing partners (including network advertising companies, publishers, and business partners)
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
- Data analytics providers
Law enforcement agencies, courts, regulators, and government authorities as described in our Privacy Policy
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Social networking services
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Consumer data vendors
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
Political committees, non-profit advocacy groups, and similar organizations
Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Inferences
5. Sale or Sharing of Personal Information
In connection with certain of our products and services, we may sell certain personal information we obtain about you for monetary consideration. We also may share your personal information for cross-context behavioral advertising purposes. You have the right to opt out of such sale of your information or sharing of your personal information, as detailed below.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the last updated date of this California Consumer Privacy Notice), we may have shared or sold your personal information with certain categories of third parties, including as described in our Privacy Policy and below, including for the business purposes described above.
If you do not want information collected by cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager. If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
Categories of Third Parties
Categories of Personal Information
Our affiliates
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Third-party vendors who provide services on our behalf
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants)
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Marketing partners (including network advertising companies, publishers, and business partners)
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Data analytics providers
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Social networking services
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
Consumer data vendors
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
i360 Clients (For-profit companies, political committees, non-profit advocacy groups, and similar organizations)
- Identifiers
- Additional Data Subject to §1798.80
- Protected Classifications
- Commercial Information
- Online Activity
- Geolocation Data
- Employment Information
- Education Information
- Inferences
We do not have actual knowledge that we sell or share the personal information of minors under 18 years of age.
6. California Consumer Privacy Rights
You may have certain choices regarding our use and disclosure of your personal information, subject to relevant exceptions under applicable law, as described below.
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you.
Correction: You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Limit Use and Disclosure: You have the right to limit the use and disclosure of your sensitive personal information.
Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your personal information.
Shine the Light Request: You have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the preceding calendar year, and (2) the identity of those third parties.
How to Submit a Request: To submit an access, correction, or deletion request, limit use or disclosure, or to opt-out of the sale of your personal information, click here to submit your request via the i360 California Consumer Privacy Act California resident request system or call our CCPA information line at 1-844-611-2737.
To submit a CCPA request as an authorized agent on behalf of a consumer, click here to submit the consumer’s request via the i360 California Consumer Privacy Act California resident request system or call our CCPA information line at 1-844-611-2737. Proof of your status as an authorized agent will need to be submitted along with your request through the i360 California Consumer Privacy Act California resident request system. We may also require for the consumer to verify their own identity directly with us prior to actioning requests submitted by authorized agents.
To submit a Shine the Light request, please contact us at [email protected] and include the phrase “Shine the Light request” in the subject line.
Verifying Requests: To help protect your privacy and maintain security, we may take steps directly or through a third-party identity verification vendor to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of, or deletion of your personal information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us related to products or services we offer you. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Notice is available in alternative formats upon request by emailing [email protected] or contacting our CCPA information line at 1-844-611-2737.
