CCPA Compliance

Notice to California Residents: Your California Privacy Rights

California Consumer Privacy Act:

The California Consumer Privacy Act (“CCPA”) provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “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.” Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to notice at collection regarding the categories of personal information collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

  • Personal identifiers:
    • We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
    • We collect payment information when you provide it to us, which may be your credit card number or other payment method, when you complete a transaction. We use this information to facilitate payments and transactions.
    • We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
    • We collect your Device ID automatically when you use our Services. We use this information to monitor your use, and the effectiveness of, our Services, to identify you, and to provide you with targeted information and offers.
  • Commercial information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Services and to provide you with targeted information, advertisements, and offers.
  • Internet or other electronic network activity information: We collect information about your browsing history, search history, interaction with our websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
  • Geolocation data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.
  • Audio, electronic, visual, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image, or similar information. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

Right to know about personal information collected, disclosed, or sold

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.

Verification procedures

In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:

  • Providing personal identifiers we can match against information we may have collected from you previously, and
  • Asking you to confirm your request using the email address or telephone account stated in the request.

If you have authorized someone else to make requests on your behalf, we will require that you provide statements confirming the identity and authority of that person by email at: privacy@clekinc.com.

 

Right to know/access information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

 

Right to request deletion of information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

 

Right to information regarding participation in data sharing for financial incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

 

Right to opt out of sale of personal information to third parties, “Do Not Sell My Info”

California law requires that we maintain a method that allows you to opt out of the sale of your Personal Information in the future, which can be facilitated by emailing us at: privacy@clekinc.com with the subject line “Do Not Sell My Info”.

  • As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months: Internet or other electronic network activity information, and inferences drawn from the above. We “sold” each category to advertising networks, data analytics providers, and social networks.
  • The business or commercial purposes of “selling” personal information is for third party companies to perform services on our behalf, such as: marketing, advertising, and audience measurement.
  • We do not “sell” personal information of known minors under 16 years of age.

Among other rights provided for in our Privacy Policy, you may:

  • Choose to control targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers by visiting the Digital Advertising Alliance
  • You may also opt-out by disabling cookies in your browser, or by utilizing browser add-ons that block cookies on your device.

Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.

We may also disclose information to other entities when required by law or to protect Clek or other persons, as described in our Privacy Policy.

How to submit a request

You may submit a request to exercise your rights by:

Emailing us at: privacy@clekinc.com

By telephone at: 1-866-656-2462

 

Authorized agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual deliver statements to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.