CALIFORNIA PRIVACY NOTICE

Date Last Updated: June 21, 2023

If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) provide you with certain rights regarding your personal information, including the right to know about personal information collected, disclosed, or sold; the right to request that we delete personal information that we have collected from you; the right to update or correct your information; the right to opt-out of the sale or sharing of your personal information; the right to limit our use of your sensitive personal information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also visit our Privacy Policy to learn more about how we protect your information.  

Any capitalized terms in this California Privacy Notice that are not otherwise defined have the same meaning as they do in the CCPA or in our Privacy Policy.  

Collection of Personal Information 

If you visit, use, or interact with our Services, we may collect 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 (“personal information”). We may have collected the following categories of personal information about you over the past 12 months:

  • Identifiers, such as your name, email address, shipping address, billing address, and Internet Protocol (IP) address.

  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, telephone number, and payment information. 

  • Commercial information, such as your purchase history. 

  • Internet or other electronic network activity information, such as your cookies and IP address. 

  • Inferences drawn from any of the information identified above.

We collect the personal information listed above from the following sources:

  • From you directly, when you provide it to us.

  • From other sources in the course of our business. 

  • Automatically from your browser or from our Services. 

Disclosure of Personal Information

In the last 12 months, we may have disclosed for our business purposes the following categories of personal information subject to the CCPA:  

  • Identifiers, such as your name, email address, shipping address, billing address, and Internet Protocol (IP) address.

  • Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, telephone number, and payment information. 

  • Commercial information, such as your purchase history. 

  • Internet or other electronic network activity information, such as your cookies and IP address. 

  • Inferences drawn from any of the information identified above.

We may have disclosed or shared any of the information listed above with: 

  • Third-party service providers supporting the operation of our Services. 

  • Google Analytics, to help analyze the data that we collect.

  • Other third parties for a legal purpose (such as in response to a court order or to defend against a legal claim).

  • Other third parties when necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party.

  • Other third parties (including Merchants) when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Purposes for Collection, Use, and Disclosure of Personal Information

We may collect, use, or disclose your personal information to the entities listed above for the following purposes: 

  • Provide you with our Services;

  • Respond to your questions or requests concerning the Services; 

  • Fulfill the terms of any agreement you have with us; 

  • Fulfill your requests for our Services or otherwise complete a transaction that you initiate; 

  • Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails; 

  • Improve our artificial intelligence and machine learning; 

  • Deliver confirmations, account information, notifications, and similar operational communications; 

  • Improve your user experience and the quality of our products and Services; 

  • Comply with legal and/or regulatory requirements; 

  • Aggregate and deidentify information; 

  • Benchmark results for our customers; 

  • Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services; 

  • Create new products and Services; and 

  • Manage our business.

Your Rights 

If we maintain personal information about you that is subject to the CCPA, you may exercise certain rights in connection with this data if you are a California resident. 

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”).  Once we receive and confirm your verifiable consumer request, we will disclose to you: 

  • The categories of personal information we collected about you. 

  • The categories of sources for the personal information we collected about you.

  • The categories of personal information that we have disclosed for a business or commercial purpose.

  • Our business or commercial purposes for collecting, selling, or sharing personal information.

  • The categories of third parties with whom we share or disclose that personal information.

  • The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/contractors to delete) your personal information from our records, unless an exception applies. 

Right to Correct

California residents have the right to correct or amend the personal information we have on file (“Right to Correct”). You may correct or amend by logging into your account or by contacting us using the information below.

 

Right to Opt-Out of Sale or Sharing

The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their personal information (“Right to Opt Out”). In the last 12 months, we have not sold or shared any categories of personal information subject to the CCPA. We also do not have actual knowledge that we sell or share the personal information of California residents under the age of 16. 

  

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides California residents with the right to limit the use of their “sensitive personal information” to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations.

 

We do not use your sensitive personal information for any purposes outside of those permitted by § 7027(m).

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. 

Exercising Your Rights

If you are a California resident and wish to exercise any of the above rights, you may submit a request to us by email at support@subscribfy.com. 

When you submit a request, we will confirm your identity by asking you to provide information associated with what we have on file for you, including your name, email address, and other identifying information. We may ask you for additional information to verify your identity or to comply with your request.

Please note that, in many situations, we may be processing your personal information in our role as a service provider to our customers and may not be able to directly comply with your request.

Authorized Agent

You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.

Data Retention

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it.  When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

Shine the Light Law

In addition to the CCPA, California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. We do not disclose your personal information for these purposes.

Contact for More Information 

If you wish to contact us regarding this California Privacy Notice, you may do so by email at  support@subscribfy.com.