California Privacy Notice

FAROPOINT PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last updated: May 2023

This Privacy Notice applies to Consumers residing in the State of California (hereinafter the “California Privacy Notice” or “Notice”), who are entitled to certain rights and protections with respect to their Personal Information under the California Consumer Privacy Act (the “CCPA”) as well as the California Privacy Rights Act (“CPRA” and together with the CCPA, the “California Regs”).

The terms “personal information”, “business purpose”, “commercial purpose”, “sale” and “service provider” as used in this Notice have the meanings ascribed to them in the California Regs. Capitalized terms used but not defined in this Privacy Notice will have the meanings set out in the Faropoint Privacy Policy (the “Privacy Policy”). If there is any conflict or inconsistency between the terms of this Notice and the Privacy Policy, the terms of this Notice will govern.

1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT FROM CALIFORNIA CONSUMERS
In the preceding 12 months, we may have collected the following categories and types of personal information from California consumers, and intend to continue doing so subject to the requirements under the CCPA:
Identifiers, such as name, email addresses.
Customer characteristics, which includes the categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including without limitation, for employment candidates, education and employment history, and characteristics of protected classifications under California law, such as gender and age (over 40).
Commercial information, including purchasing habits, such as the products you have ordered or considered, as well as your purchasing history.
Technical Identifiers, such as internet and other similar network activity, such as browsing history and cookie history.
Geolocation data.
Inferences, which are drawn from the above information to create consumer profiles reflecting certain preferences and behaviors and customized content/offerings.

For more information about the types of personal information we collect, please see the “Personal Information Faropoint Collects” section in our Privacy Policy.

2. INCENTIVES
From time to time and subject to the requirements of the California Regs, we may offer you certain incentives, financial or otherwise, to encourage you to share your personal information with us, which we’ll use to send you future marketing communications. You always have the right under the California Regs to opt-out of receiving these marketing communications and/or to request the deletion of your personal information from our records, as we describe below.
3. BUSINESS OR COMMERCIAL PURPOSE FOR COLLECTING, SHARING AND SELLING INFORMATION.
We collect and share your personal information for the following business and commercial purposes: to authenticate you when you use our Website and/or Platform, to provide customer support, to audit our products and services, to detect security incidents, to debug and fix errors associated with our Website and/or Platform, research, activities to maintain the quality of our Website and/or Platform, to provide personalized marketing offers and programs, and other commercial events that occur from time to time. In addition, we’ve shared your personal information with those service providers that have assisted us with carrying out the foregoing.

We do not make your data publicly available, and we do not act as data brokers and we do not trade in your data. However, certain standard generally accepted business practices may be deemed as “Sale” of data under the California Regs, such as when we utilize third party service providers that provide us with services, while they retain certain rights to use your data for their own business needs (e.g., Google Analytics, Facebook, fraud detection services, etc.).

If you are a California customer, you have a right under the new definition of “sale”, to request to opt-out of certain data transfers and sharing of personal activities which we operate. Please refer to Section F of our Privacy Policy – “Notice to California Residents” below, for information on how you can exercise your rights. For more details on how and to whom we share your data please refer to our Privacy Policy.

4. YOUR CALIFORNIA CONSUMER RIGHTS.
California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request once in any 12-month period.

You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information, the categories of personal information we have disclosed and “sold” about you in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months.
If you are a California consumer, you also have the right to request deletion of your personal information (subject to certain exceptions), to opt out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights (unless permitted by applicable law, such as if the differences are reasonably related to your information).

Our Website does not sell (as “sell” is traditionally defined) your personal information. That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money. However, under California Privacy Notice, sharing information for instance for advertising purposes may be considered a “sale” of “personal information.” If you’ve visited our Website within the past 12 months, under the California Regs personal information about you may have been “sold” to our advertising or other partners for their own use. California residents have the right to opt out of the “sale” of personal information, and we’ve made it easy for anyone to stop the information transfers that might be considered such a “sale” from our website or mobile app. And just for clarification, sharing your personal information with our service providers that may send you an email communication on our behalf isn’t considered a “sale” under the California Regs.

California consumers may make a rights request by submitting an online request . Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and account id (which is required only if you already have an account with us). If you have an account with us, you can find your account id on your main account page after you log in.

Additionally, California consumers may opt-out of the “sale” of information as described above, by changing their Privacy Preferences.

Please note that by opting out of the sharing of your personal information considered as sale as defined by the California Regs:

You may still see some tailored advertising that third parties may have previously collected unless you opt out of all interest based advertising (see our cookie policy or visit www.aboutads.info/choices);

We will still share your personal information with our service providers to provide the services on our websites and mobile apps; and
These settings may not persist if you clear your cookies, switch devices, or switch browsers. If you access our websites from other browsers or devices, you will also need to make this selection on each browser and device. If you delete or clear cookies, you’ll need to click the button again the next time you visit. If you delete or clear your cookies, that will delete our opt-out cookie and you will need to opt out again. If you have previously requested that we do not sell your personal information, your request remains in effect until you tell us otherwise.