This Privacy Policy for California Residents describes the privacy practices of Affidio Inc., (“Affidio”) and applies solely to the Personal Information (as defined below) that Affidio may collect and/or use relating to users of the Affidio website (“Site”), who reside in the State of California (“Users,” “You” or “Your”). The California Consumer Privacy Act of 2018 (“CCPA”) requires certain notice(s) and may provide specific rights to California residents, which are detailed below.

By using the Site and providing Affidio with Personal Information You agree to the practices described in this Privacy Policy and to any updates to the Privacy Policy that may be posted from time to time. To make sure You stay informed of all changes, You should check the Privacy Policy periodically.

DEFINITION OF PERSONAL DATA: For purposes of this Privacy Policy, “Personal Information” shall mean information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, household, or device.

Personal Information for purposes of this Privacy Policy does not include:

• Your name, phot and/or other information about you included in news or editorial content.
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Other information excluded from the CCPA’s 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 covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

CALIFORNIA “SHINE THE LIGHT” LAW/YOUR CALIFORNIA PRIVACY RIGHTS: California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers who are California residents, to request and obtain from Affidio once a year, free of charge, information about the categories of Personal Information (as defined in the Shine the Light law), if any, that Affidio disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Disclosure requirements apply only if Affidio shares its consumer’s Personal Information with third parties for them to directly market their own products to those consumers, As opposed to third parties assisting Affidio with its own business. If you are a California resident and would like to make such a request, contact us as provided in below.

PERSONAL INFORMATION WE COLLECT: The following is a list of categories of Personal Information which may have been collected within the last twelve (12) months. The categories and examples provided in this chart are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact collected but reflects Affidio’s good faith belief to the best of its knowledge that some of that information may have been collected. Affidio will update this disclosure from time to time as appropriate.

TABLE A

In response to a verified consumer request for categories of information collected, we will investigate and provide a response to You.

Sources of Personal Information

• Directly from You. For example, from forms You complete, subscriptions You purchase or comments you provide.
• Indirectly from You. For example, from observing Your usages and purchases.
• From third parties. For example, third party social networking providers and advertising companies, affiliates and service providers who provide services or information to Affidio. If You do not want information from social networks collected, You should review and adjust Your privacy settings on those networks as desired before using or connecting them to Affidio Software Products.
• From publicly available sources. For example, online database searches.

You agree that You will provide to Affidio only your own Personal Information, or the Personal Information of those whom You have the legal right to provide (such as in Your capacity as a legal guardian).  You agree to provide Affidio with accurate Personal Information.

USE AND DISCLOSURE (“SALE”) OF PERSONAL INFORMATION: The CCPA broadly defines the term “sale” to mean:

“Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer’s personal information with a third party, whether for valuable consideration or for no consideration, for the third party’s commercial purposes.”

Within this meaning, Affidio may have disclosed (as that term is defined by the CCPA) Personal Information in the categories listed in TABLE A above from users of the Site and users of the Software Products within the last twelve months where such disclosure may fall within the CCPA’s definition of a “sale.” Affidio may have received some kind of compensation in return for sharing Personal Information.

Use of Personal Information for Business Purposes or Commercial Purposes.

Affidio may use or disclose Personal Information collected for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.

• Auditing Interactions with Consumers. For example: monitoring traffic to the Software Products, counting ad impressions, and auditing legal and regulatory compliance.
• For example, maintaining the safety, security, and integrity of Software Products, databases and other technology assets and Affidio’s business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests or court orders and to comply with any applicable laws and regulations.
• Debugging/Repair. For example, identifying and repairing errors in that may be found in the Software Product
• Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
• Performing Services. For example, creating, maintaining, customizing and securing accounts, processing purchases, transactions, and payments, hosting Software Products, fulfilling orders, managing databases, performing analyses, billing, and marketing services such as managing promotions and contests.
• Internal Research and Development. For example, testing, research, analysis, and product improvement and development.
• Other Commercial Purposes such as, delivering to You, promotions, contests, marketing and advertising that Affidio and its affiliates and marketing partners believe may be of interest to You.
• For the purpose of evaluating or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Affidio’s assets, in which Personal Information held is among the assets transferred.

Disclosing Personal Information to Other Parties

Affidio may disclose your Personal Information to the following parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:

• Our affiliates, marketing partners, and advertising and content providers
• Service providers: such as data processors, hosting companies, customer service providers, contractors, agents or sponsors who help manage or provide Affidio products and services.
• Advertisers, advertising technology companies, analytics companies and other third parties with whom Affidio has business relationships.
• Government regulators.
• Our legal advisors and parties involved in a legal process.
• To an entity involved in the sale of Affidio’s business
• Third parties to whom You or Your agents authorize us to disclose your Personal Information to.

In order to provide advertisements and content that are more relevant to You, Affidio and its advertising and content providers may collect certain types of Personal Information when You use the Site (such as, by way of example, Your email, the IP address of Your device, the identifier on Your mobile device, or cookies stored on Your device). Affidio or its advertising and content providers may combine this information with other information collect through other sources, and may share the information collect with third parties to provide interest based or targeted advertising and content

YOUR CCPA PRIVACY RIGHTS AND CHOICES: California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:

Right to Know about Personal Information Collected or “Sold”

You have the right to request that Affidio disclose certain information to You about the collection and use of Your Personal Information over the past 12 months. After receiving and confirming Your verifiable request, Affidio will disclose to You within the time required by the CCPA, the relevant information.

Right to Request Deletion of Personal Information

You have the right to request that Affidio delete any of Your Personal Information collected from You and retained, subject to certain exceptions, including if such information is needed for a reason related to Affidio’s business, such as:

1. providing the Products to You;
2. detecting and resolving issues related to security or functionality;
3. complying with legal obligations;
4. conducting research in the public interest;
5. exercising free speech or ensuring another’s exercise of free speech; or
6. using the information for internal purposes that a consumer might reasonably expect.

After receiving and confirming Your verifiable request, Affidio will delete Your Personal Information from its records in the time and manner required by the CCPA, subject to any limitations or exceptions under law.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable request to Affidio. You may only make a request for access or data portability twice within a 12-month period. The request must provide sufficient information that allows Affidio to reasonably verify that You are the person about whom Personal Information was collected. This means that in making a request You may be required to provide information needed to verify Your identity.

Affidio cannot respond to requests or provide Personal Information if it cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You. If we are unable to verify your identity, we reserve the right to deny the request.

If You use an authorized agent to submit any type of request, Affidio may require that You provide the authorized agent written permission to do so; and verify Your own identity directly with Affidio. Affidio will not require these steps if proof has been received that You have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465. Affidio may deny a request from an agent that does not submit proof that they have been authorized by You to act on your behalf.

Once Your identity has been verified, Affidio will respond to your request as appropriate. To the extent permitted by applicable law, Affidio may charge a reasonable fee to comply with Your request.

DO NOT TRACK DISCLOSURES: “Do Not Track” (DNT) is a privacy preference You can set in Your browser if You do not want online services to collect and share certain kinds of information about Your online activity from this party tracking services.  Affidio does not currently respond to DNT signals or other mechanisms.

DO NOT SELL MY PERSONAL INFORMATION: The CCPA requires businesses to provide a way for consumers to opt out of the “sale” of their Personal Information. California residents may exercise there “Do Not Sell” Right by contacting Affidio at the address or email set forth below.

CONTACT US

AFFIDIO INC.
(PLACE ADDRESS HERE)
(PLACE PHONE NUMBER HERE)
(PLACE EMAIL ADDRESS HERE)