Last Revised: January 28, 2021
Any terms defined in the California Consumer Privacy Act (“CCPA”) have the same meaning when used in this California Specific Privacy Notice. California residents with disabilities may access this notice in an alternative format by emailing us at: firstname.lastname@example.org.
Boardroom will continue to revise our California Specific Privacy Notice to reflect the development of the CCPA and our understanding as to how it relates to our data practices.
- USE OF THE SITE BY MINORS
You must be the age of Majority or older (18 in most states of the United States; older in some jurisdictions) to create an account on the Website, if account creation becomes available. While individuals under the age of 18 (but not younger than 13) may utilize the Website, they must do so only with the consent and involvement of a parent or legal guardian, under such persons account and otherwise subject to our Terms and Conditions. Boardroom does not seek through this Website to gather personal information from or about persons under the age of 13. If we become aware that you are under the age of Majority and are attempting to or have submitted personal information via the Website, we will not accept such information and we will take steps to remove such information from our records. This may involve us having to access and verify your age and other relevant details.
- INFORMATION WE MAY COLLECT FROM YOU
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, 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, email address, unique personal or online identifier, IP address, account name, Social Security number driver’s license number, passport number, date of birth or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||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.||YES|
|C. Protected classification characteristics under California or federal law.||Age, 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).||NO|
|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.||Physiological, behavioral and biological characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity or other identifier or identifying information, such as, fingerprints, or and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|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)).||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.||YES|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
- WE OBTAIN THE CATEGORIES OF PERSONAL INFORMATION LISTED ABOVE FROM THE FOLLOWING CATEGORIES OF SOURCES:
- When you sign up for our newsletter, we ask for information such as your email address. We also acquire your Internet protocol address and/or mobile device identification, which certain jurisdictions consider to be PI because it could be used to identify an individual or device if it were combined with other identifying information.
- We may capture user information when users send us questions or comments via e-mail. PI collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an e-mail will not enroll you on our e-mail list unless you specifically request it.
- ● For purchases made through the Website, a third-party payment processor will collect your full name, email address, postal address, contact details and credit or debit card information (“Billing Information”). This record will be stored and processed in the United States and other countries (see further below under “How we use information about you” and “How we store and process information about you”). By making a purchase, you grant to us and to all other persons and entities involved in the operation of the Website, the right to use, store, monitor, retrieve and transmit your account information in connection with the operation of the Website and as otherwise provided herein. You also agree that such access and use of your Personal Information is governed by their privacy policies. We are not responsible or liable for the content, activities or privacy policies of any third-party sites. Accordingly, please refer to their respective privacy policies.
- We do not request on or through the Website other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government issued identification (e.g., your social security card, drivers’ license, or passport), although we reserve the right to do so when such information is necessary to verify your Billing Information.
- We take reasonable precautions to protect the confidentiality and security of your Personal Information by using industry recognized security safeguards such as site monitoring, secured networks and servers, firewalls and/or encryption. When you enter PI, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. Your credit card information is always encrypted during transfer over networks. Unfortunately, no method of transmission over the Internet is completely secure. Therefore, while we strive to protect your Personal Information within industry standards, we cannot guarantee its absolute security.
- We may also obtain your Personal Information through your use of social media depending on your settings or the privacy policies of these websites. To change your settings on these services, please refer to their respective privacy notices.
Note, if you do not provide the mandatory Personal Information for a particular activity, we may not be able to offer the required information for you to engage in that activity.
- HOW WE USE THE INFORMATION WE COLLECT
If you elect to provide Boardroom with Personal Information, we may use it as needed to provide goods or services to you. These uses are based in our legitimate business interests in providing goods or services to you and/or fulfillment of our contractual obligation to deliver the goods or services you have requested. We have balanced these business needs carefully with your privacy rights and these uses do not improperly infringe on your privacy and confidentiality rights. We may use your Personal Information in the following ways:
- to provide users with news, events, personalized offers, promotions and other relevant information. Such direct marketing shall be sent in response to a request from a user to receive newsletters, marketing emails or similar communications, or when a user has expressed interest in such content or services;
- to contact users with updates and relevant information about our content, products and/or services because they have signed up to do so through our Website;
- to quickly process user requests for information and to allow us to respond efficiently to user questions;
- to monitor Website statistics;
- to respond to or satisfy legal requirements, such as a court order, a subpoena, or a law enforcement agency’s or other public agency’s request;
- to help prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Website, to help protect the security or integrity of our Website, or to enable us to take precautions against liability;
- to provide information to service providers or such companies who provide support for the operations of our Website and who do not use or disclose the information for any other purpose;
- to administer a contest or other promotion, survey or other features; and
- to allow us to disclose your information to the extent permitted by law.
- HOW WE SHARE INFORMATION
- Affiliates and Sponsors. In connection with our content and advertisements, which you would only receive after opting-in, our Affiliates and/or Sponsors may collect Personal Information. Such provides may include Google and Facebook. Please visit their respective privacy policies for more information regarding their data collection and use practices.
- Subsidiaries, Website Consultants and Service Providers. We may disclose Personal Information to our subsidiaries, third party consultants and service providers (such as providers of hosting, support, returns, maintenance, third party payment processing agencies, and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and the Website;
- Reorganization or Sale. In the event that we merge with or become a part of another organization, or in the event that we are sold, we sell all or substantially all of our assets, or we are otherwise reorganized, the information you provide will be one of the transferred assets to the acquiring or reorganized entity;
- To Help Protect Minor Users of Our Website. In the event that the safety of our users is threatened, and we are able to do something about that by sharing PI with third parties, we reserve the right to do so. This may be done to prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our Website, to help protect the security or integrity of our Website, or to enable us to take precautions against liability;
- As Otherwise Allowed by Law. We may transfer Personal Information to third parties where we are expressly authorized by applicable law to do so;
- Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer that aggregated information to third parties;
- ● We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Website becomes public information and may be available to visitors to the Website and to the general public. In addition, when you choose to make a posting on such services certain Personal Information will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose Personal Information about you, or any other information, on the Website. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD-PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE WEBSITE; and
- ● With your express consent.
- YOUR RIGHT TO ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information 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 (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, a separate list 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.
- Please note that we do not sell your Personal Information.
- 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.
You may object to Boardroom using your Personal Information for the above purposes at any time by emailing us at: email@example.com. If you do so, Boardroom will cease using your Personal Information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such Personal Information is permitted to be used by Boardroom for another purpose set out in this California Specific Privacy Notice or Boardroom determines and demonstrates a compelling legitimate interest to continue in processing your Personal Information.
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 (Cal. Penal Code § 1546 seq.).
- 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 verifiable consumer request to us by emailing firstname.lastname@example.org.
Regarding our marketing materials, you may also withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of each email or by emailing email@example.com. If an individual withdraws their consent to receiving marketing emails, we will still be able to send them essential service communications that are necessary for the performance of our services.
- AUTHORIZED AGENTS
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 if you provide the authorized agent written permission signed by you or pursuant to a valid Power of Attorney. You may also make a verifiable consumer request on behalf of your minor child. When you use an authorized agent to submit a request, we may require you to:
- Provide the authorized agent signed permission to do so.
- Verify their own identity directly with the business.
- Directly confirm with the business that they provided the authorized agent permission to submit the request.
- VERIFIABLE CONSUMER REQUESTS
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 (such as your name and email address).
- 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. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
- RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within 45 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 by mail or electronically, at your option. 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 and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.
- SALE OF PERSONAL INFORMATION
We do not sell Personal Information.
We will not discriminate against you for exercising any of your CCPA rights. 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.
- CHANGES TO THIS CALIFORNIA SPECIFIC PRIVACY NOTICE
We may, in our sole discretion, modify or revise this California Specific Privacy Notice at any time. Such changes or updates are effective immediately after we give notice of the change or update, which we may do so by revising the Last Revised date at the top of the California Specific Privacy Notice or by otherwise posting on the Website, by email, conventional mail and/or by any other means that provides reasonable notice. If you are subscribed to one of our mailings, you must provide us with your correct email address and make sure that email from us is not filtered from your inbox by your ISP or email software. You agree that your use of the Website, after the date such notice is posted, means that you accept and agree to be bound by such modifications or revisions to the California Specific Privacy Notice. You agree that we shall not be liable to you for any damages that might result from any changes to this California Specific Privacy Notice, if any.
- CONTACT US
Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to firstname.lastname@example.org.
Copyright © 2021 Boardroom 35 LLC. All Rights Reserved.