Your California Privacy Rights Notice
Information Spojiti Collects:
Spojiti collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as the following:
- 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; and
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, Spojiti may have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|A. Identifiers||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.|
|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.|
|C. Protected classification characteristics under California or federal law||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).|
|D. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|E. Professional or employment-related information||Current or past job history or performance evaluations.|
|F. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.|
Spojiti obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you if you provide your Personal Information to Spojiti.
- Directly and indirectly from activity on Spojiti’s Sites.
- Directly from Spojiti’s prospects, customers, or their agents.
- Indirectly from Spojiti’s prospects, customers, or their agents. For example, through information Spojiti collects from Spojiti’s customers in the course of providing services to them.
Information Spojiti Uses:
Spojiti may use or disclose the Personal Information Spojiti collects for one or more of the following purposes:
- To fulfill or meet the reason you provided the information.
- To provide, support, personalize, and develop Spojiti’s Sites, products, and services.
- To create, maintain, customize, and secure your account with Spojiti.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve Spojiti’s responses.
- To personalize your experience using Spojiti and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through Spojiti’s Sites, third-party websites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of Spojiti’s Sites, products, and services, other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve Spojiti’s Sites, 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.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Spojiti’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Spojiti is among the assets transferred.
Spojiti will not collect additional categories of Personal Information or use the Personal Information Spojiti has collected for materially different, unrelated, or incompatible purposes without providing you notice.
Information Spojiti Shares:
Spojiti may disclose your Personal Information to a third party for a business purpose. When iSpojiti discloses Personal Information for a business purpose, Spojiti enters 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.
Spojiti discloses your Personal Information for a business purpose to the following categories of third parties:
- Spojiti’s subsidiaries, affiliates, or their or Spojiti’s successors or assigns.
- Spojiti’s contractors, business partners, service providers, and other third parties Spojiti uses to support Spojiti’s business providers.
- A potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of Spojiti’s assets (including in the event of a reorganization, dissolution or liquidation).
- Any competent law enforcement body, regulatory, government agency, court or other third party to: (i) comply with any court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply Spojiti’s Terms and Conditions or terms of any other agreement; and (iii) protect the rights, property, or safety of Spojiti or others.
- Any other person or organization with your consent to the disclosure and/or to fulfill the purpose for which you provide it.
In the preceding twelve (12) months, Spojiti may have disclosed the following categories of Personal Information for a business purpose:
- California Customer Records Personal Information categories.
- Protected classification characteristics under California or federal law.
- Internet or other similar network activity.
- Professional or employment-related information.
In the preceding 12 months, Spojiti has not sold any Personal Information in the traditional sense. To learn more about Spojiti’s approach to California’s “Do not sell my personal information” requirement, why it applies to your use of our Sites, and how you can exercise this right, please visit Your California “Do Not Sell My Personal Information” Rights Notice. There we explain that how California has defined as “sales” under CCPA certain transfers of Personal Data between Spojiti and our affiliates are integral to the product and services we offer our users.
Your Rights and Choices:
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights:
You have the right to request that Spojiti disclose certain information to you about Spojiti’s collection and use of your Personal Information over the past 12 months. Once Spojiti receives and confirms your verifiable consumer request, Spojiti will disclose to you:
- The categories of Personal Information Spojiti collected about you.
- The categories of sources for the Personal Information Spojiti collected about you.
- Spojiti’s business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom Spojiti shares that Personal Information.
- The specific pieces of Personal Information Spojiti collected about you (also called a data portability request).
- If Spojiti 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:
You have the right to request that Spojiti delete any of your Personal Information that Spojiti collected from you and retained, subject to certain exceptions. Once Spojiti receives and confirms your verifiable consumer request, Spojiti will delete (and direct Spojiti’s service providers to delete) your Personal Information from Spojiti’s records, unless an exception applies.
Spojiti may deny your deletion request if retaining the information is necessary for Spojiti or Spojiti’s service provider(s) to:
- Complete the transaction for which Spojiti collected the Personal Information , provide a good or service that you requested, take actions reasonably anticipated within the context of Spojiti’s ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform Spojiti’s 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 Spojiti’s product functionalities.
- 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 et. 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 and data portability rights described above, please submit a Data Usage Report request to firstname.lastname@example.org
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.
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 Spojiti to reasonably verify you are the person about whom Spojiti collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows Spojiti to properly understand, evaluate, and respond to it.
Spojiti cannot respond to your request or provide you with Personal Information if Spojiti 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 Spojiti. Spojiti will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
To exercise your data deletion right, please submit a verifiable consumer request to Spojiti via:
Response Timing and Format:
Spojiti will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Spojiti requires more time, Spojiti will inform you of the reason and extension period in writing, which may be extended for up to an additional forty-five (45) days (90 days in total from the date of receipt of your request).
Any disclosures Spojiti provides will only cover the 12-month period preceding the verifiable consumer request’s date of receipt. The response Spojiti provides will also explain the reasons Spojiti cannot comply with a request, if that is the case. For data portability requests, Spojiti 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.
Spojiti does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded and unreasonable. If Spojiti determines that a fee is warranted for your request, Spojiti will inform you the reasons Spojiti has warranted such fee and provide you with an estimated cost of such fee prior to completing your request.
Spojiti will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Spojiti 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.
Spojiti may, however, offer you certain financial incentives as part of a financial incentive program (“Program”) permitted under the CCPA that could alter the prices, rates, or quality levels of the goods or services you receive. Any CCPA-permitted Program Spojiti offers will reasonably relate to your Personal Information’s value and contain written terms describing the material details of such Program. Your prior “opt in” consent, which you may revoke at any time, is required to participate in a Program.
Other California Privacy Rights:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Spojiti’s Sites users, that are California residents, to request certain information pertaining to Spojiti’s disclosure of Personal Information to third parties for their direct marketing purposes. Please contact Spojiti at email@example.com, to make such a request.
Privacy Notice Changes:
Spojiti reserves the right, in its sole discretion, to update, change, modify, add, or remove portions of this California Privacy Notice from time to time and without notice. No amendment, modification, extension, limitation, waiver, or termination of this California Privacy Notice by you shall be valid except with the written consent of Spojiti. Spojiti encourages you to periodically review this page for the latest information regarding Spojiti’s California Privacy Notice, which applies to California residents. Your continued use of the Sites is subject to the most current effective version of Spojiti’s California Privacy Notice. If you object to this California Privacy Notice after it becomes effective for you, you may no longer use Spojiti’s Sites and services.
If you have any questions or comments about this notice, the ways in which Spojiti collects and uses your Personal Information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact Spojiti at: