Privacy Notice - California CCPA

 

PRIVACY NOTICE-CALIFORNIA CCPA

Effective on: January 1, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statements of UberMedia, Inc. (collectively, “we,” “us,” or “our”) and applies solely to Consumers who reside in the State of California (“consumers” or “you”). This Notice does not apply to any employees. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Terms defined in the CCPA have the same meaning when used in this notice.

CCPA

Personal Information is defined in the CCPA and include the following:

Category Examples
 Identifiers. A unique personal identifier, Internet Protocol address, email address, account name, or other similar identifiers.
 Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Social Security 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.
 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, gender, pregnancy or related medical conditions, sexual orientation, veteran or military status, genetic information (including familial genetic information).
 Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Browsing history Internet activity information including browsing history, search history, interaction with a website or with advertisements.
 Geolocation data. Physical location or movements.
 Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information under the CCPA does not include publicly available information from government records; de-identified or aggregated consumer information or information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Personal Information We Collect

We collect the following categories of Personal Information under CCPA from Consumers within the last twelve months:

For   Personal Information
Advertising and Business Intelligence Services Device information such as mobile advertising device ids (MAIDs), ip addresses, and browser type

Geolocation data (if enabled) associated with a device id. such as latitude-longitude, GPS source, postal code, and country code

Interaction with advertisements including advertising click-stream data

 Our Mobile Apps

 

Your Twitter handle

Mobile advertising device ids (MAIDs), ip addresses, and location data (if enabled) associated with a device id;

Browsing history with Apps and interaction with advertisements  including advertising click-stream data

  Our Websites Your ip address and your interactions with the Sites

 

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from Products (mobile apps) and our SDKs
  • Indirectly from our demand and supply partners of mobile advertising networks and from select data partners.
  • Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.

 

Use of Personal Information

As discussed more fully in our Privacy Policies, most of the information we collect and use is de-identified and aggregated information, such as de-identified categories of app use and jittered geolocation information associated with a de-identified device id. We also provide partners with de-identified device id information, except in the case when the actual device id is needed, such as for targeted advertising and for matching and measurement of advertising. De-identified and aggregated information is not Personal Information, and we use such information in a number of ways for our business intelligence services as we discuss in our Privacy Policy, including for marketing and targeted advertising and data analytics.

We do not share your twitter handle other than to authenticate your use on our Twitter-based Apps.

Your Rights and 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.

Information Request

You have the right to request that we disclose certain information about our collection and use of your Personal Information about you over the past 12 months. To provide this information we need your mobile advertising device id (which is a unique id number assigned to each device).  We ask you to complete a form and then follow the instructions to provide us with a legible image of your mobile advertising device id.  Once we receive and confirm your 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.
  • If we sold or disclosed your Personal Information for a business purpose, we will also identify the categories of Personal Information we shared by such sale.

 

Access Right

CCPA provides consumers with rights to request access of the Personal Information about them when the consumer can verify that they are the rightful owner of the information requested.  We need your mobile ad id in order to identify any device in our systems but we don’t have a way to confirm that the device mobile ad id actually belongs to the particular person making the request.  That’s because we do not collect the information that would match the device id to the actual owner (such as a name or account information) to allows us to confirm that the consumer requesting the information is the same consumer that owns the device.  It would require us to actually collect more Personal Information to try to verify who the device owner is, such as requesting a full name, address, and receipt of purchase of the device.  Additionally we want to avoid the potential risk of providing a requestor who provides a mobile ad id with the Personal Information that belongs to another individual.  For example, a requestor can take a snapshot of the device id of his/her friend and request her Personal Information without her consent.  Accordingly, in a matter of caution, we are not able to provide the particular file associated with any particular mobile advertising device id.  If you are uncomfortable with our having any Personal Information about you, please send us a request to opt out or to delete your information.

 

Opt out of Sales and Deletion Request Rights

You have the right to request that we opt out your Personal Information from any sales.  You also have the right to request that we delete your Personal Information. Once we receive and confirm your verifiable consumer request, we will honor your request (and direct our service providers to as well).

We may deny your deletion request if we cannot verify the device id or it meets one of the exemptions under CCPA.  We will also retain a copy of our records related to processing your request.

 

Exercising Access, Opt Out, and Deletion Rights

To exercise the rights described above, please visit our Consumer Choices pages. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request if we cannot verify your mobile device identity to confirm the Personal Information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in the request to process the request and to a retain a record of the request.

 

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 do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this privacy notice, we will post the update information on our website.

Contact Information

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 do not hesitate to contact us.