This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Sermo (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). In the event of a conflict between this Privacy Statement and the Privacy Policy, this Privacy Statement shall control with respect to the personal information of California residents.
1. Information We Collect
We have collected the following categories of personal information from consumers within the last twelve (12) months:
| A. Identifiers | A real 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. | YES |
| B. Personal information categories | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | YES |
| C. Protected classification characteristics | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information. | YES |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
| I. Professional or employment information | Current or past job history or performance evaluations. | NO |
| J. Non-public education information | Education records directly related to a student maintained by an educational institution or party acting on its behalf. | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Note: Certain information that we collect identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, except for publicly available information, deidentified or aggregated consumer information and information excluded from CCPA scope (such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data) (“personal information”).
2. Categories of Sources
We obtain the categories of personal information listed above,
- Directly from you – for example, from your registration, your personal account information, documents you send to us and your participation in market research studies.
- Indirectly from you – for example, through your interactions with our website and social platform (see our cookie policy) or
- Information from third parties that interact with us in connection with our Services – for example, third party sources used to verify and validate your registration information
3. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our services, events or news, that may be of interest to you. These communications may be conveyed through a variety of channels, subject to applicable law, including emails and may contain advertisements and other promotional materials from third party sponsors.
- To provide our partners with engagement effectiveness metrics and minimal personal data for performance assessment purposes.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including incentives payment for your participation in marketing research studies.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a business combination, such as a merger or sale.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice
4. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: Personal information categories
Category C: Protected classification characteristics
Category F: Internet or other similar network activity
Category H: Sensory data
We disclose your personal information for a business purpose to the following categories of third parties, as all more fully described in our Privacy Policy:
- Our partners, including certain health care companies with which we have a relationship;
- Service providers; and
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
5. Sale of Information
We do not sell Personal Information. As such, no category of Personal Information has been sold in the preceding 12 months.
6. Your Rights and Choices
Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. 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.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you in a readable format (also called data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing specifics on: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a request to us by either clicking here, visiting us at https://support.sermo.com/ or Emailing us at: support@sermo.com.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format.
We endeavor to respond to a verifiable consumer request within 28 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.
We do generally do not charge a fee to respond to your verifiable consumer request. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
Sermo is a free platform and we plan on keeping it this way. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you 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.
However, Sermo may provide a different level of Services if the difference is reasonably related to value provided by the data [for example: by not accepting cookies, we cannot tailor content and increase user experience].