Effective Date: September 1, 2019
If you live in California and have an established business relationship with us, you can contact us to request a list of the personal information we have shared with third parties for their marketing purposes. Please use the Contact Us information provided below or you may email us directly at email@example.com with the subject line "Privacy Concerns." We will respond within 45 days from receipt.
1.0 INFORMATION WE COLLECT
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:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
Please note, the categories above are as specified by the CCPA and Crowd Factor® may not collect every type of information specified in each category as it regards to the information we gather on you.
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 2009 (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 you. For example, from electronic documents that our clients provide to us related to the services for which they engage with us.
- Indirectly from our Clients. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (crowdfactor.com). For example, from submissions through our website’s contact form or website usage details collected automatically.
2. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide you with information, products or services that you request from us.
- To provide you with text or email alerts, blog events, newsletters and other notices concerning our products or services, or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- 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.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
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.
3. 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.
Disclosures of Personal Information for a Business Purpose
We disclose your personal information for a business purpose to the following categories of third parties:
- Service Providers
- Data Aggregators
In the preceding twelve (12) months, Crowd Factor has disclosed personal information for a business purpose in the following categories: (see examples of categories above)
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold any personal information.
4. Your Data Rights & Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Where we are relying on your consent to process your personal data, you can withdraw your consent to our processing your personal data at any time. You can do this by contacting us at firstname.lastname@example.org, or by the mailing BC United LLC PO Box 100322 Denver, CO 80250. In certain circumstances, we can process your personal data without your consent in line with the lawful processing requirements. These include (amongst other reasons) where processing is necessary to carry out a contractual obligation between us, to comply with a legal obligation, or to protect your vital interests.
4.1. Request right to what information we have about you over the past 12 months. You have the right to request that we 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, 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.
- If we sold or disclosed your personal information for a business purpose and 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.
4.2. Request to correct inaccurate or incomplete personal data. We would seek to amend the data as soon as possible and usually within forty-five (45) days, unless the request is complex.
4.3. Request to erase your personal data. Commonly referred to as the "Right to be Forgotten. This right is only applicable where there is no compelling reason for the continued processing of your personal data. There are some circumstances where this right to erasure does not apply and in such cases, we would notify you of the reason(s) why we need to retain your personal data (unless prevented to do so by law).
4.4. Restrict processing of your personal data where, for example, the data is inaccurate, being processed unlawfully or where the data is no longer relevant to the specific purpose for processing. In such cases, we would retain the data, but we would not process it further without your consent, or if processing your data is for establishing, exercising or defending a legal claim, or for the protection of rights of other individuals, or for public interest reasons. In such circumstances, we would let you know that we intend to lift the restriction on processing your personal data.
4.5. Request access to your personal data. Your request should be made to us in writing by email to email@example.com. We may ask you for proof of your identity before providing you with the data. 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 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.
4.6. Request not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
4.7. Right to data portability. Obtain and reuse your personal data for your own purposes across different services. This right is only applicable to data that you have provided to us, where we are processing the data based on your consent or for the performance of a contract and when the processing is carried out by automated means. Where this right applies, the data will be provided to you in a structured, commonly used and machine-readable format.
5. 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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 requests warrants a fee, we will tell you why we made that decision and provide you wit a cost estimate before completing your request
6. Changes to this policy
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
Data Protection Officer:
BC United LLC
PO Box 100322
Denver, CO 80250