Ekata Privacy Notice for California Residents

Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Ekata’s general Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Any terms defined in the California Consumer Privacy Act of 2018 (CCPA) have the same meaning when used in this notice.

Information We Collect

Ekata has collected the following categories of consumer personal information within the last twelve (12) months:

Category Examples
A. Identifiers. A real name, alias, postal address, Internet Protocol address, email address, , or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, and telephone number.  Also, if consumers purchased a product or service from Ekata, a bank account number, credit card number, or debit card number.

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

C. Protected classification characteristics under California or federal law. Age (40 years or older).
D. Commercial information. Records of products or services considered, purchased, or obtained from Ekata.  Records of the occurrence of transactions conducted with Ekata customers, or other purchasing or consuming histories or tendencies.
E. Biometric information None.
F. Internet or other similar network activity. Browsing history, search history, and information on a consumer’s interaction with Ekata’s Web site. Information on a consumer’s interaction with an online application of an Ekata customer.
G. Geolocation data. Physical location (IP address).
H. Sensory data. None.
I. Professional or employment-related information. Current or past job history, if a consumer applies for a position with Ekata.
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) None.
K. Inferences drawn from other personal information. Profile reflecting a person’s predispositions and behavior when conducting online transactions with Ekata or Ekata’s customers.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope.

Ekata obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Web site and through cookies and other similar technology.
  • Other businesses.

Use of Personal Information

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

  • To verify your identity and to prevent fraud;
  • To fulfill or meet the reason you provided the information;
  • To respond to your inquiry;
  • To provide, support, personalize, and develop our Web site, products, and services;
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud;
  • To help maintain the safety, security, and integrity of our Web site, products and services, databases and other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our Web site, products, and services;
  • 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; and
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ekata’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ekata about our Web site users is among the assets transferred.

Ekata 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.

Sharing Personal Information

Ekata may disclose your personal information to a service provider, business, or third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out  below). 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 or as otherwise allowed by the CCPA.

Disclosures of Personal Information for a Business Purpose

In the last twelve (12) months, Ekata has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

In the past twelve (12) months, we have shared personal information with the following categories of parties for a business purpose:

  • Service providers;
  • Data analytics providers; and
  • Ekata’s wholly-owned subsidiaries.

Sales of Personal Information

In the past twelve (12) months, Ekata has sold the following categories of personal information:

  1. Identifiers.
  2. California Customer Records personal information categories.
  3. Protected classification characteristics under California or federal law.
  4. Commercial information.
  5. Internet or other similar network activity.
  6. Inferences drawn from other personal information.

In the past twelve (12) months, Ekata sold personal information for the purposes of identity verification, fraud prevention, or data enrichment to the following categories of parties:

  • Other businesses; and
  • Third parties.

Your Rights and Choices

This section describes consumer CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

Consumers have the right to request that Ekata 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 (see Exercising Rights), 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 (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Consumers have the right to request that Ekata delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Personal Information Sales Opt-Out

If you are a consumer 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the right to “opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do not sell my personal information.

Exercising Rights

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

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.

Non-Discrimination

We will not discriminate against a consumer for exercising any of your CCPA rights.

Changes to Our Privacy Notice

Ekata reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Web site following the posting of changes constitutes your acceptance of such changes.