California Consumer Privacy Act of 2018 Statement (V1.0 Effective October 22, 2020)

This California Consumer Privacy Act of 2018 (the “CCPA”) Statement applies to California resident and supplements our Privacy Policy.  California law provides specific rights to “consumers” as defined under the CCPA and other California privacy laws.

Under California law, Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household.

WHAT WE COLLECT AND HOW WE USE IT

Over the past twelve (12) months, NetEnrich has collected the types of Personal Information or Identifiers as stated in the What We Collect section of our Privacy Policy from various sources as identified in the How We Collect and Collection and Use of Personal Information When Responding To Your Request For Information, Order, or Support and Marketing sections of our Privacy Policy.

We use the information collected for the purposes described in Collection and Use of Personal Information When Responding to Your Request for Information, Order, Support, Sharing Personal Data with Third Parties, Contacting Employees of Our Clients and Prospects, Partners and Suppliers Visitor sections of our Privacy Policy.

Netenrich does not plan to collect other types of personal information or use the above types of information for materially unrelated purposes, except with prior notice. We may disclose or have disclosed personal information based on a consumer’s consent or a written agreement with one or more of our service providers for a business purpose in the 12 months predating this updated Privacy Policy.

WE DO NOT SELL PERSONAL INFORMATION

As of the Effective Date of this Statement, and for the twelve (12) month period predating it, we do not and have not sold the Personal Information of California residents that we have collected.

YOUR RIGHTS

The CCPA provides consumers with (i) the right to request that we disclose to you certain information about our collection and use over the past 12 months, and (ii) the right to request that we delete your Personal Information, subject to certain exceptions.  We will not discriminate against if you exercise any of your rights under California privacy law.

Right to Disclosure under CCPA

Pursuant to the CCPA, upon a valid and verified request by a consumer, Netenrich will disclose the following information to such consumer about Netenrich’s collection and use of that consumer’s personal information over the past 12 months:

• • • The categories of personal information we collected about such consumer.
    • The categories of sources for the personal information we collected about such consumer.
    • Our business or commercial purpose for collecting or selling (if applicable) such personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about such consumer (i.e. a data portability request).

Right to Delete

Pursuant to the CCPA, upon a valid and verified request by a consumer, Netenrich will delete Personal Information about such consumer, except for situations when such information is necessary for Netenrich to: provide you with a requested good or service; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your current expectations based on your relationship with us.

EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise your right to request the deletion of your CCPA Personal Information, either click here or contact us at datasecurity@netenrich.com. Requests for deletion of your CCPA Personal Information are generally free.

Generally, only a consumer or a person registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.

A consumer 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 Netenrich to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
• Describe a consumer’s request with sufficient detail that allows Netenrich to properly understand, evaluate, and respond to it.

We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

RESPONSE TIMING AND FORMAT

We will respond to a verified consumer request within a reasonable time in accordance with applicable law. We will deliver our written response by mail or electronically. 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 a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.

CONSUMERS UNDER 16 YEARS OLD

As of the effective date stated herein, we do not have actual knowledge that we collect CCPA Personal Information of consumers under 16 years of age. If we learn that we have collected CCPA Personal Information from a child under age 16, we will delete that information as quickly as possible.

CHANGES TO OUR PRIVACY STATEMENT

We reserve the right to amend this Statement in our sole discretion and at any time. When we make changes to this Statement, we will provide notice by email or through a notice on our website homepage.

CONTACT INFORMATION

If there are any questions or comments about this statement, please contact us at datasecurity@netenrich.com.