CCPA NOTICE FOR CALIFORNIA CONSUMERS

ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS 

 

Under the California Consumer Privacy Act (“CCPA”), we are required to provide certain information to California consumers about how we handle their personal information that we have collected, whether online or offline. For purposes of this section of our privacy policy, and per the CCPA, “personal information” is broadly defined to include any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. 

 

Categories of Personal Information that We Collect, Disclose, and Sell 

 

The table below discloses the categories of personal information, as defined by CCPA, about California consumers that we collect, sell, and disclose for a business purpose. Since this section also includes offline data, this section may be broader than the disclosures set forth above. 

 

Category

A. Identifiers.

EXAMPLE: 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.

COLLECTED?: YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

EXAMPLE: 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. Some personal information included in this category may overlap with other categories.

COLLECTED?: YES

C. Protected classification characteristics under California or federal law.

EXAMPLE: 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 (including familial genetic information).

COLLECTED?: NO

D. Commercial information.

EXAMPLE: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

COLLECTED?: 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.

COLLECTED?: NO

F. Internet or other similar network activity.

EXAMPLE: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

COLLECTED?: NO

G. Geolocation data.

EXAMPLE: Physical location or movements.

COLLECTED?: YES

H. Sensory data.

EXAMPLE: Audio, electronic, visual, thermal, olfactory, or similar information.

COLLECTED?: NO

I. Professional or employment-related information.

EXAMPLE: Current or past job history or performance evaluations.

COLLECTED?: NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

EXAMPLE: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

COLLECTED?: NO

K. Inferences drawn from other personal information.

EXAMPLE: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

COLLECTED?: NO

 

Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA's scope, like:

    • 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our customers or their agents. For example, from information that you provide to us related to the Services.

  • Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing Services to them.

  • Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.

  • From third-parties that interact with us in connection with the services we perform. For example, from outside companies we may use to assist us in providing you with Services.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To meet or fulfill the reason you provided the information to us.

  • To communicate with you about the Services, including Service announcements, updates or offers.

  • To provide support and assistance for the Services.

  • To create and manage your Account or other user profiles.

  • To personalize website content and communications based on your preferences.

  • To process orders or other transactions.

  • To respond to user inquiries and fulfill user requests.

  • To improve and develop the Services, including testing, research, analysis and product development.

  • To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.

  • To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • For any other business purpose stated when collecting your Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (“CCPA”).

 

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.

 

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at info@somisomi.com

 

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:

 

We disclose your personal information for a business purpose to the following categories of third parties:

 

In the preceding twelve (12) months, we have not sold any personal information.

 

California Consumer Rights

 

If you are a California resident, you have certain rights related to your California Personal Information. 

  • Section 100 Rights. You have the right to request that we disclose to you the specific species of personal information we have collected.

  • Section 105 Rights. You have the right to request that we delete California Personal Information about you which we have collected from you.

  • Section 110 Rights. You may request that we disclose to you:

    • the categories of California Personal Information we have collected about you;

    • the categories of sources from which the California Personal Information is collected;

    • our business or commercial purpose for collecting or selling California Personal Information;

    • the categories of third parties with whom we share California Personal Information; and

    • the specific pieces of information we have collected about you.

  • Section 115 Rights. To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:

    • the categories of California Personal Information that we have collected about you;

    • the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and

    • the categories of California Personal Information about you that we disclosed for a business purpose.

  • Right to Opt Out. In addition, we may sell your information within the meaning of the California Consumer Privacy Act. You have the right to opt out of such sales here. To submit an opt-out request info@somisomi.com

 

Exercising Access, Data Portability & Deletion Rights

 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • By completing our rights request form available info@somisomi.com

  • Calling us at (213) 435-7188 

 

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.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.

 

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.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

 

Nondiscrimination

 

Subject to applicable law, we will not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:

  • Denying you goods or services;

  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Providing you a different level or quality of goods or services; or

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Financial Incentive Program

 

From time to time, we may offer financial incentives, including payments to you as compensation, for the collection of your personal information, the sale of your personal information, or the deletion of your personal information. These financial incentives include discounts, coupons, gift cards, survey rewards, and financial incentives of various forms of payment. To participate, please email us at info@somisomi.com. You may revoke your consent to participate in our financial incentive program at any time.

 

Do Not Sell My Personal Information

 

If you are a California resident, you have the right to opt out of our sales of certain information relating to individuals and households subject to the California Consumer Privacy Act. To exercise this opt-out right, whether you have an account or not, please submit a request via info@somisomi.com. If you do not have an account, include your name and email address or mailing address.

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