CCPA Privacy Statement
Last modified: February 2023
1. Information We collect
We collect information that identifies, relates, describes, and references can be associated, or can reasonably be linked, directly or indirectly, to a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers in the past twelve (12) months:
- identifiers (e.g. real name, alias, online identifier, IP address, email address, or other similar identifiers);
- personal Information Categories Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). Some Personal Information included in this category may overlap with other categories;
- internet or Similar Network Activity (e.g. browsing history, search history, interactions with a website, application, or advertisement);
- geolocation data (e.g. physical location or movements).
We obtain the categories of personal information listed above from the following categories of sources:
- data provided directly by You: You provide some of this data directly as you use the Defined.ai products, complete a custom/contact request or subscribe to our newsletter;
- data provided indirectly by you as information that we automatically collect from your use of the Website;
2. Use of personal information
Depending on your interactions with Defined.ai, we may use or disclose the Personal Information we collect about you for one or more of the following business purposes:
- to provide you with our Services, which include, but are not limited to, communicating with you, maintaining accurate records, and personalizing your experience with the Services;
- to improve our Services by analyzing how site visitors access and use our Services, both on an aggregated and individualized basis;
- for our direct marketing efforts, such as sending news, newsletters, email marketing material, targeted advertising, and, if you have provided us prior express written consent to receive marketing messages via telephone, text messages, or calls;
- for other purposes permitted by law, such as compliance with a law, regulation, legal process, or court order, or the fulfillment of any other purpose with your consent.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without notifying You.
3. Sharing personal information
We may disclose your personal information to third party for commercial purposes. When we disclose personal information for a commercial purpose, we enter into a contract that describes the purpose and requires the recipient to keep such personal information confidential and not use it for any purpose except to perform the contract.
Defined.ai may disclose personal information for a business purpose to the following categories of third parties:
- law enforcement, regulatory, and other governmental agencies.
- business partners.
- parent entities, affiliates, and subsidiaries.
- cookie information recipients, subject to their respective privacy notices.
In the preceding twelve (12) months, Defined.ai disclosed the following categories of Personal Information for business purposes:
- California Customer Records Personal Information categories.
- Internet or other similar network activity.
- Geolocation data.
In the preceding twelve (12) months, we have not sold any personal information.
4. Your rights and choices
The CCPA provides consumers (California residents) specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Each of these rights is subject to our receipt of a verifiable consumer request.
5. Right to disclosure
You have the right to request disclosure of certain information about our collection and use of your Personal Information over the past 12 months, such as:
- the categories of Personal Information we have collected about you.
- the categories of sources for the Personal Information we have collected about you.
- our business or commercial purpose for collecting or selling such Personal Information.
- the categories of third parties with whom we share such Personal Information.
- if we sold or disclosed your Personal Information for a commercial purpose, two separate lists disclosing (i) sales, identifying the categories of personal information that each category of recipient purchased; and (ii) disclosures for a commercial purpose, identifying the Personal Information categories that each category of recipient obtained.
Defined.ai is only required to respond to two disclosure requests within a 12-month period.
6. Right to access
You have the right to request that we provide you with access to specific pieces of Personal Information that we have collected about you over the past 12 months (also called a data portability request). If you submit a right of access request, we will provide you with copies of the Personal Information requested in a portable and easily usable format. Please note that Defined.ai is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Defined.ai is only required by law to respond to two access requests within a 12-month period.
7. Right to deletion
You have the right to request the deletion of any Personal Information that we have collected and retained from you, with certain exceptions. Defined.ai may permanently delete, deidentify, or aggregate the Personal Information to response to a deletion request. If you submit a deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
8. Submit a Consumer Privacy Request
To exercise any of the above rights, please submit a verifiable consumer privacy request to Defined.ai: by email at [email protected].
We cannot respond to your request or provide you with Personal Information unless we can verify your identity and your authority to make the request and confirm that the Personal Information relates to you. A verifiable consumer privacy request must be made:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collect the Personal Information or an authorized representative.
- describe your request in sufficient detail to allow us to properly understand, evaluate, and respond appropriately to it.
You do not have to sign up with Defined.ai to make a verifiable consumer privacy request. We will only use Personal Information provided in a verifiable consumer privacy request to verify the identity or authority of the requester to make the request.
8.2. Authorized Agent
You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”) may make a verifiable consumer request related to your Personal Information. If you wish to have an Authorized Agent to make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will continue to require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.
9. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we need more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures provided by us will only cover the 12-month period preceding to receipt of the consumer’s verifiable request. If we cannot comply with part or all of Your requests, we will explain the reasons in our response.
We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we decided 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 law, we will not do any of the following as a result of your having exercised your right under the CCPA:
- deny you goods or services.
- charge you different prices or rates for goods or services, including granting discounts or other benefits or imposing penalties.
- provide you with 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.
11. Changes to our Privacy Statement
12. Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at: [email protected].