WideOrbit California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA. This Notice does not apply to our employees or contractors where the Personal Information we collect about those individuals relates to their current or former role with us.

For the purposes of this Notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act and its implementing regulations, as amended or superseded from time to time (collectively, the “CCPA”).

Personal Information does not include information that is:

Lawfully made available from government records.
Deidentified or aggregated.
Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information we collect and disclose, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding twelve months since this Notice was last updated. The chart also details the categories of Personal Information that we “sell” or “share” for purposes of cross-context behavioral advertising (as defined by the CCPA), including within the preceding 12 months since this Notice was last updated.

Category	Disclosed to Which Categories of Third Parties for Operational Business Purposes	Sold to Which Categories of Third Parties	Shared with Which Categories of Third Parties for Cross-Context Behavioral Advertising
A. Identifiers Examples: 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.	• Advertising Providers • ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Example: Name	• ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
C. Characteristics of Protected Classifications under California or Federal Law Examples: Age (over 40), and sex (including gender)	• Advertising Providers • ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
D. Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	• Advertising Providers • ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
E. Internet or Other Electronic Network Activity Information Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.	• Advertising Providers • ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
F. Geolocation Data Example: Precise physical location.	N/A	N/A	N/A
G. Sensory Information Examples: Audio, electronic, visual, thermal, olfactory, or similar information.	N/A	N/A	N/A
H. Professional or employment-related information. Examples: Job application or resume information, past and current job history, and job performance information.	• Vendors • Third Parties as Legally Required	N/A	N/A
I. Inferences Drawn from Personal Information Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	• Advertising Providers • ISPs • Analytics Providers • Social Networks • Vendors • Integrated Third Parties • Third Parties as Legally Required	N/A	N/A
J. Sensitive Personal Information	N/A	N/A	N/A

Purposes for the Collection, Use, Sale, and Sharing of Personal Information

We collect, use, sell, share, and disclose your Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information for:

Providing Services: Providing our services.
Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks
Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
Personalization: Personalizing your experience on our services such as presenting tailored content.
Job Applications: Processing your job application.
Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction. We may also disclose Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Sources of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

You/Your Devices: You or your devices, such as through our website, emails, social media, and any other online or offline interactions.
Affiliates.
Public: Publicly accessible sources, including Google, AdWords, and LinkedIn.

Purposes for the Collection and Use of Sensitive Personal Information

We may use Sensitive Personal Information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

The length of time we provide services to you or have an ongoing relationship with you (for example, for as long as you have an account with us, or while we are processing your job application) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Your Privacy Rights under the CCPA

If you are a California resident, you may exercise the following rights.

Right to Know and Access.

You may request information regarding the: (1) categories of Personal Information we collected about you; (2) business or commercial purposes for collecting, selling, or sharing Personal Information about you; (3) categories of sources from which we collected your Personal Information; (4) categories of Personal Information about you that we sold or “shared” for purposes of cross-context behavioral advertising and the categories of third parties to whom we sold or “shared” such Personal Information; (5) categories of Personal information about you that we otherwise disclosed, and the categories of third parties with whom we disclosed such Personal Information; and (6) specific pieces of Personal Information we have collected about you.

Right to Delete.

Subject to certain exceptions, you may request that we delete Personal Information about you that we have collected from you.

Right to Correct.

You may request that we correct inaccuracies in your Personal Information.

Verification.

Requests for access, deletion, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as Full Name, Phone Number, Email Address, Job Title, Company Name, Country, Product of Interest, Industry/Vertical for WideOrbit products/solutions, to verify your identity and protect against fraudulent requests. We cannot fulfill your request if we cannot verify your identity or authority to make the request.

How to Submit Access, Deletion and Correction Requests.

To exercise these rights under the CCPA, please visit https://www.wideorbit.com/privacy/request/ or call our toll-free number (800) 587-1705.

Right to Opt Out of Sale and/or Sharing.

Click here to opt out of any future sale of your Personal Information and/or any future “sharing” of your Personal Information for purposes of cross-context behavioral advertising (as defined by the CCPA).

Right to Non-Discrimination.

You have the right not to be discriminated against for exercising your CCPA privacy rights.

Authorized Agent.

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Your California Privacy Rights.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Your California Privacy Rights” or confirm that you provided the agent permission to submit the request.

Your Rights under the Shine the Light Act.

If you are a California resident, you may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the Contact Information section below.

Minors

We do not knowingly sell or “share” (for purposes of cross-context behavioral advertising as defined by the CCPA) the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Contact Information

If you have any questions, comments, or concerns about this Notice or our processing activities, please email us at privacy@wideorbit.com.

Last Reviewed and Updated: December 15, 2023