Privacy Center Overview

 

Webbula’s Privacy Center Overview

Webbula is committed to the responsible use of the information we obtain through our online offline data resources.  Webbula strives to protect the data we maintain and process through the implementation of industry standard security measures, technology controls and operational processes. This Privacy Center is an extension of Webbula’s continued commitment of being at the forefront responsible data practices.

Using the navigation tabs at the top, you will have access to the following:

  • Privacy Notice:  An explanation of the data we collect, how the data is managed, and your data rights.
  • Consent Preferences: Our consent manager for cookies and similar technologies used on this site.
  • Opt-Out Request: Remove your information of yours we’ve collected for our cloudHygiene and insightData services.
  • Data Access Request (for California Residents): Request to see what information of yours we’ve collected and submit updated information to make our cloudHygiene and insightData services even better.
  • Transfer Request: Initiate a transfer of your data to another entity.
  • Submit A Complaint: Notify usc of a privacy issue so we can make things right.
  • CCPA Addendum: This section applies if you are a resident of California. 

Privacy Inquiries

You may contact us by email at privacy@webbula.com or by postal mail at:

Webbula, LLC
ATTN: Privacy/Compliance
5000 Stonewood Drive
Suite 310
Wexford, PA 15090
 
Copyright 2009 – 2020, Webbula, LLC. All rights reserved.
DATE OF LAST MODIFICATION January 2, 2020


Privacy Notice

 

Webbula refers Webbula, LLC., which is sometimes referred to as “we,” “us,” or “our,” depending on the context. Webbula has developed this Privacy Notice to explain how we collect, retain, process, share and transfer your personal information when you visit https://webbula.com (“Website”) and to help you make informed decisions when using our Website. This Privacy Notice is designed to cover our Website. We also collect and use personal information in a variety of ways beyond our Website.

 

  1. COLLECTION OF PERSONAL INFORMATION

Our Website collects IP addresses and other personal information from individuals who visit. Personal information is any information from which a third party would be able to identify you. This collection could occur, for instance, when you submit an inquiry about our services or registering for an event or webinar. When you provide information to us, it is likely to include a variety of information, including your name, contact information and what you are inquiring about or registering for.  When you provide information to us, we will add your information to our customer relationship files and may market to you in the future, such as to send you information about product updates and future events. We may do this through various channels, including email, direct mail, and display media. We may also collect information automatically from your browser, such as through cookies, pixels and similar technologies (see section 6 for a description).

  1. USE OF INFORMATION

In general, Webbula uses the information that it receives or collects to provide, improve, evaluate and maintain its Website. We may also use the information for marketing and client services. (Although we do use personal information to provide services to customers, we do not sell, lease, distribute or transfer the personal information we collect through the Website.) See “Individual Rights” below for more information about how you can control your personal information and other rights you may have regarding your personal information.

  1. DISCLOSURE OF INFORMATION

Webbula may share, sell, and / or license information from and about you in a variety situations, including: (1) to comply in good faith with law enforcement requests, subpoenas, or other legal process, or otherwise to comply with legal requirements; (2) to protect our interests, the Website, or other users; (3) as part of the sale of Webbula or its assets, including in the course of due diligence leading up to any such sale; (4) with its parent, subsidiaries, or affiliates; (5) with third parties for commercial use; and (6) with our third party providers, such as attorneys, accountants, hosting services and other contractors. We may also share information that is anonymous, aggregated and/or de-identified for various business and commercial purposes, where legally permissible. As described above, we sometimes work with other companies to provide services. For instance, we share information we collect or receive with service providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, otherwise assisting us to provide, develop, maintain and improve our services.

  1. INDIVIDUAL RIGHTS

Keeping your information up-to-date is very important. If you are an individual consumer interested in having your data removed from Webbula’s Data Enhancement and Online Audience Targeting services, please see “Opt-Out Status” below. Please see “Interest-Based Advertising, Your Ad Choices and Related Technology” for more information about interest-based advertising and further opt-out choices.

Any personal information collected by or through our Site will be used  for the purpose it was provided and as described in this Privacy Notice. Once personal information is no longer necessary, we will destroy the Personal Information in accordance with our record retention and destruction policy.

Some jurisdictions (state, federal, national and international), such as California, Canada, and the European Economic Area (under the General Data Protection Regulation (“GDPR”)), provide individuals with certain rights regarding their personal information. To exercise any rights your jurisdiction may provide, contact us at:

Webbula, LLC
ATTN: Privacy / Compliance
5000 Stonewood Drive
Suite 310
Wexford, PA 15090
privacy@webbula.com

As examples, GDPR provides European residents with the following individual rights.

  • Being informed about your personal information, including the right to understand what personal information we collect about you as well as how we use and share your personal information. This Privacy Notice provides you with this information.
  • Viewing and obtaining a copy of the personal information we maintain about you.
  • Amending or revising the personal information we maintain about you.
  • Having personal information we keep about you erased (also known as the right to be forgotten).
  • Objecting to the use of your personal information for direct marketing.
  • Restricting our use of the personal information we maintain about you.
  • Transferring the personal information we maintain about you to another entity.
  • Objecting to our use of the personal information we maintain about you.
  • Objecting to automated decision making or profiling.
  • Filing a complaint with us or the appropriate governmental entity.

We may require that you verify your identity before exercising your individual rights.

  1. INTEREST-BASED ADVERTISING, YOUR AD CHOICES AND RELATED TECHNOLOGY

We sometimes provide our information (including information we collect in the course of providing our services, i.e., not simply data collected through our website) for use in digital advertising. When we do this, we work with a service provider (and sometimes multiple service providers) who replaces personally identifiable information such as an email address with a de-identified hashed value. That or other de-identified values are then combined with other data (for instance, other identifiers, demographic or interest-based data), linked to online identifiers (such as a cookie-based identifier or mobile ad identifier), and used to target interest-based ads on web and mobile advertising platforms.

To learn more about the cookies used on this site, see Cookie Use (section 60) in this privacy notice. Cookies are small pieces of information stored on your computer and used to make certain websites more operational. For example, they can be used to determine what webpages are being visited, how long you are on a certain page or remember browsing history or login information. To learn more about cookies, go to http://www.allaboutcookies.org/.

Do not track signals and requests are sent from your browser to websites you visit indicating you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. Our Website does honor do not track signals or requests.

To opt-out of interest-based advertising through web-based means, you may go to industry-wide opt-out portals operated by the Digital Advertising Alliance (http://digitaladvertisingalliance.org/) or the Network Advertising Initiative (http://optout.networkadvertising.org/#!/). Please note that when you opt-out, an opt-out cookie is placed on your browser. If you delete your cookies, or replace your browser, you will need to opt-out again.

To opt-out of interest-based advertising through mobile apps (also called “cross-app” advertising), you may go to the “opt-out” instruction in your device settings.

  1. COOKIE USE

We use cookies to ensure your consent preferences are honored and to improve your website experience. The following lists the cookies currently in use along with the originator, purpose, description and expiration:

Necessary / Regulatory

Cookies that are necessary for the site to function properly and ensure your consent choices are saved for GDPR regulations.  The Necessary / Regulatory cookies used on this sire are:

  • gdpr – This cookie  associated with Webbula, LLC through this website’s consent manager. This cookie is used to request and store your consent of Webbula’s Privacy Notice and cookie choices. It is set to expire after 1 year.

Statistics / Analytics (Google Analytics)

Google Analytics provides anonymous statistical information for us. They process IP addresses and information from other cookies used on our sites so we know how many page views we have, how many users we have, what browsers they are using (so we can target our resources in the right way to maximize compatibility for the majority of our users) and, in some cases, in which country, city or region they are located.

  • _ga
    This cookie is associated with Google Universal Analytics. This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. It is set to expire after 2 years.
  • _gid
    This cookie is associated with Google Universal Analytics. This cookie is used to distinguishes unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. It is set to expire after 24 hours.
  • _gat
    This cookie is associated with Google Universal Analytics, it is used to throttle the request rate – limiting the collection of data on high traffic sites. It expires after 1 minutes.
  1. LINKS TO OTHER WEBSITES

We may provide links to websites that are owned or operated by other companies (third party websites). When you use a link online to visit a third party website, you will be subject to that website’s privacy notice and security practices. Webbula does not control or endorse these third party websites and is not responsible for any content contained on any such website.

  1. SECURITY

We use various electronic, physical, technical, and procedural safeguards to protect and limit access to the information you provided to us via this online service. Unfortunately, no data transmission or storage system can be guaranteed to be 100 percent secure; you therefore should not rely on our (or any) security protocols to be foolproof. Additionally, please note that information you send to us electronically may not be secure when it is transmitted to us because we do not control the security of your delivery channel.

  1. CHILDREN’S PRIVACY

Our online services are not intended for children, and Webbula provides no products or service geared towards children. Our website at www.webbula.com does not knowingly solicit or collect personal information online from children under age 18.

  1. EU-US PRIVACY SHIELD

Privacy Shield Certification. As a business subject to the enforcement and investigatory powers of the Federal Trade Commission, Webbula, Inc. has certified our compliance with the EU-US Privacy Shield Framework with respect to the personal client data we receive from the relevant European countries, effective as of the date our certification is posted at https://www.privacyshield.gov/list. You can learn more about the Privacy Shield program at https://www.privacyshield.gov. We may alternatively process personal data our clients in the EU submit via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. (As to any third-party service providers we may use to process information subject to the Privacy Shield, we may certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.)

Accessing Your Data: European residents may have certain legal rights to access certain personal data and to obtain its correction, amendment, or deletion. You may contact us at the contact information below to request access, correction, amendment, or deletion. Because our personnel have limited rights to identify and access an individual user’s personal data that our client has submitted to us, and because we process that data on behalf of our clients, we may first refer you to the client who submitted your data, and we will support them as needed in responding to your request.

Resolution of Complaints. In compliance with the EU-US Privacy Shield Principles, Webbula commits to resolve complaints about your privacy and our collection or use of your personal information. If you have any concerns or complaints, please contact us as described at the end of this Privacy Notice, and we will work with you to resolve your issue. Webbula has further committed to refer unresolved Privacy Shield complaints to The Data & Marketing Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://thedma.org/resources/consumer-resources/privacyshield-consumers/ for more information or to file a complaint. The services of The Data & Marketing Association are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

  1. DATA ACCURACY AND DISCLAIMER

Webbula endeavors to maintain only true and accurate consumer information. Please note, however, that Webbula secures its information from a variety of third party sources. Neither Webbula nor its employees, directors, agents, licensors, third party information providers, or vendors warrant that the information is accurate or error free. If you have concerns regarding the accuracy of your information or use of such information, you may opt-out.

Click the “Opt Out Request” tab in Webbula’s Privacy Center for instructions on requesting an opt-out.

  1. OPT-OUT STATUS

If you are an individual consumer and can provide us with sufficient identity verification, you may request to opt-out, which means Webbula will not use the information in its provision of Data Enhancement and Online Audience Targeting services.

Click the “Opt Out Request” tab in Webbula’s Privacy Center for instructions on requesting an opt-out.

To learn about methods of “opting out” of online advertising, including that facilitated by many of the partners we may work with, please see “Interest-Based Advertising, Your Ad Choices and Related Technology.”

We may send marketing materials to those who have affirmatively opted-in to receiving marketing materials from us. You can opt-out by contacting us at privacy@webbula.com or at the information provided at the end of this Privacy Notice.

  1. INTERNATIONAL TRANSFERS

We store information received through or by our Website in the United States. If you are providing the information from another country, you agree to and understand that the information will be transferred, stored and used in the United States.

  1. CALIFORNIA RESIDENT PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To review your access, data portability, and/or deletion rights visit our Addendum.
 
    15. CHANGES TO PRIVACY NOTICE

We may change this Privacy Notice at any time. Any changes will become effective when we post the revised Privacy Notice.

 

     16. CONTACT INFORMATION

You may contact us at:

Webbula, LLC
ATTN: Privacy / Compliance
5000 Stonewood Drive
Suite 310
Wexford, PA 15090
privacy@webbula.com

DATE OF LAST MODIFICATION January 2, 2020



Opt-Out Request

 

ABOUT OUR OPT-OUT

When you submit an Opt-Out Request to us, the personal information you provide will be used to search our databases to determine what data, if any, is maintained in our systems and associated with that combination of information.

When You Submit Name and Address in an Opt-Out Request.  Most of the information that we collect and use is grouped around or linked to name and address combinations.  Therefore, for most of our services, we can only opt out combinations of name and address.  For instance, if you provide us with “Jane Smith,” we will not opt out each “Jane Smith” at every address that name appears – only Jane Smith at the address you provide us with.   When we honor an Opt-Out Request, we will remove that matched data from Webbula’s Hygiene and Data services, on a going forward basis.  It may take up to [5] days to process your request. (Please note that we will do our best to match the data you submit to the data we store in our databases, but given all of the various ways that names and addresses may appear, we cannot guarantee that each misspelling or spelling variation will be accounted for.)

When You Submit Email or Phone Number in an Opt-Out Request.  If you submit an email address or telephone number with your Opt-Out Request, we will not provide that email address or phone number to a client through our data “append” services.  However, because much of our information is not linked through email (as described above, it is linked through name and address combinations), opting out an email or phone number will not have an effect on other information we hold in our databases.

We reserve the right to take steps to verify your information, through email verification (to any email that you submit).

In the event your information changes (i.e., change in address, name change), your Opt-Out will not apply to the new information:  you would need to submit a new Opt-Out Request, with your new information.

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California and EU Data Access Request

 

If you are a resident of California or the EU (or other EEA countries) you may have the right to request access to certain personal information (also called personal data) that we hold and control or manage as a business. You may do this by providing certain information in the forms below.

The information you provide will be used to search our databases to determine what data, if any, is maintained in our systems that are associated with your personally identifying information.  We also use the information you provide to us to ensure that we can verify your identity and to prevent identity fraud.  So it is in your best interest to provide accurate information.  Please be advised that the Data Access Request as described here will apply only to the information as submitted on this request (for example, prior addresses or nicknames will not be recognized by the Data Access Request process). We recommend you submit multiple Data Access Requests for past information.

Upon receipt of your request and Webbula’s proper verification of your submitted information, which may entail email, phone, and / or postal communication with you for identity verification, Webbula will then process your Data Access Request and will provide you with a CSV file containing the matching information stored in Webbula’s database(s).

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Data Transfer Request

 

The Webbula IDs you provide will be used to search our databases to determine what data in our systems are to be transferred.  We also use the additional information you provide to us to ensure that we can verify your identity and to prevent identity fraud.  So it is in your best interest to provide accurate information.

Please be advised that the Data Transfer Request as described here will apply only to the information as submitted on this request.

Upon receipt of your request and Webbula’s proper verification of your submitted information, which may entail email, phone, and / or postal communication with you and the New Data Controller (Data Recipient of Information) for identify verification, Webbula will then process your Data Transfer Request and will provide your New Data Controller with a CSV file containing the matching information stored in Webbula’s database(s).

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This form collects your contact information so that we can communicate with you and the New Data Controller to validate your identity and process your Data Transfer Request. Check out our privacy policy for more information on how we protect and manage your submitted data.
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Submit A Complaint

The information you provide will be used to search our databases to determine what data, if any, is maintained in our systems that are associated with your personally identifying information.  We also use the information you provide to us to ensure that we can verify your identity and to prevent identity fraud.  So it is in your best interest to provide accurate information. Upon receipt of your complaint and Webbula’s proper verification of your submitted information, which may entail email, phone, and / or postal communication with you for identify verification, Webbula will then communicate directly with you to address your complaint.
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This form collects and stores your contact information so that we can communicate with you to validate your identity and address your complaint. Check out our privacy policy for more information on how we protect and manage your submitted data.
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ADDENDUM FOR CALIFORNIA RESIDENTS CALIFORNIA PRIVACY RIGHTS

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT  

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) and uses our Services.  This Addendum supplements the information in the Privacy Notice. However, this Addendum is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it. 

In the below tables and sections, we describe (as required by the CCPA):

    1. Our Collection of Personal Information – the types of Personal Information (which the CCPA defines broadly) that we collect, the types of sources we collect it from.
    2. Our Disclosure and Sale of Personal Information – the types of recipients to whom we disclose or sell Personal Information.
    3. Our Business Purposes  –  our business purposes for (a) collecting and (b) sharing Personal Information, which are generally the same. 
    4. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

 

1. OUR COLLECTION OF PERSONAL INFORMATION

Depending on how you interact with us, we may collect about you the categories of information summarized in the table below. The following table also describes how we collect and use such categories of information.

Category
Categories of Sources
Identifiers
E.g., name; alias; postal address; online identifiers; IP address; telephone number; email address, mobile ad identifiers.
Data compilers and consumer data resellers, informational and retail websites, public records, government entities and other publicly available sources (such as the US Census Bureau).
Characteristics of protected classifications under California or U.S. law E.g., race; color; religion; sex/gender, marital status; military or veteran status; national origin; ancestry. Data compilers and consumer data resellers; informational and retail websites.
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Data compilers and consumer data resellers; informational and retail websites.
Internet or other electronic network activity information E.g., information on a consumer’s interaction with a website. Data compilers and consumer data resellers), informational and retail websites.
Geolocation data US Postal Service.
Professional or employment-related information E.g., job titles or categories. Data compilers and consumer data resellers, informational and retail websites.

2. OUR DISCLOSURE AND SALE OF PERSONAL INFORMATION 

We will share the information collected from and about you as discussed above for various business purposes, with service providers and with third parties including our customers.  The chart below how and with whom we share or disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” a particular category of information in the prior 12 months.

Category
Categories of Third Parties We Share With
Whether We “Sold” This Category of Personal Information in the Last 12 Months
Identifiers E.g., name; alias; postal address; online identifiers; IP address; telephone number; email address, mobile ad identifiers. Data compilers and consumer data resellers, consumer goods retailers, informational and retail websites, public records and other publicly available sources, content publishers, non-profit organizations, business-to-business companies, advertising networks, internet service providers, data analytics providers, operating systems and platforms and social networks (referred to below together as “Customer Categories”). Yes
Characteristics of protected classifications under California or U.S. law E.g., race; color; religion; sex/gender, marital status; military or veteran status; national origin; ancestry. Customer Categories Yes
Commercial or transactions information E.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Customer Categories Yes
Internet or other electronic network activity information E.g., information on a consumer’s interaction with a website. Customer Categories Yes
Geolocation data Customer Categories Yes
Inferenced data. E.g. Inferences about consumer engagement. Customer Categories Yes

We also may share any of the personal information we collect as follows:

Sharing for Legal Purposes:  In addition, we may share personal information with third parties in order to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public.  We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.   

Sharing In Event of a Corporate Transaction:  We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.

Sharing With Service Providers:    We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services. 

Sharing of Aggregate Information:  We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).   We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

3. OUR BUSINESS PURPOSES FOR COLLECTING AND SHARING PERSONAL INFORMATION

Generally speaking, we collect and share the Personal Information that we collect for the following purposes;

Our purposes for collecting, using and sharing Personal Information
Data marketing services, for example:

  • Generally, creating data marketing tools and products for our marketer clients, as more fully described in our Privacy Policy (and on our websites). This includes our provision of datasets, data “appends” (connecting data across datasets), data “scoring” (providing inferences about potential consumer behavior), data hygiene services (helping customers to evaluate, validate and correct personal information they hold), and security and anti-fraud services (helping customers to identify potentially fraudulent activity).
  • Helping our Clients identify and understand their consumers better, by providing insights about them and managing loyalty programs, as well as providing financial and other scoring products.
  • Assisting our Clients with use our Services to provide their consumers and prospects with better service, improved offerings, and special promotions, for instance, advising on which consumers or prospective consumers are most likely to be interested (or disinterested) in certain offers.
Online targeting, for example:

  • Creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences (e.g., households with prospective students). When we do this, we work with a data partner that “matches” our or other Information through de-identification techniques (such as through coded data “hashing”) with online cookies and other identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels.
  • Assisting Clients in creating “identity” graphs, to help locate users across various channels, such as based on common personal, device-based, or network-based identifiers (e.g., IP address, email address).
Additional marketing services, for example (which may overlap with “data marketing services” above):

  • Assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing.
  • Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of consumers, or which types of ads are most likely to lead to purchases.
  • Analyzing and optimizing our Clients’ (or their service providers’) proprietary databases, or helping Clients to identify and mitigate potential fraud.
  • Providing “verification” or data “hygiene” services, which is how companies update and/or “clean” their databases by either verifying or removing or correcting old, incorrect or outdated information.
Operating our Services, for example:

  • Improving, testing, updating and verifying our own database.
  • Developing new products.
  • Operating, analyzing, improving, and securing our Services.
Other internal purposes, for example:
For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We sometimes use the information collected from our own website from social networks, from other “business to business” interaction (such as at trade shows) or from data compilers for the above, as well as for our own marketing purposes.

4. YOUR CALIFORNIA RIGHTS AND CHOICES

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.  (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

a. Right to request access to your personal information

California residents have the right to request that we disclose what categories of your personal information that we collect, use, or sell.  As set forth below, you may also request the specific pieces of personal information that we have collected from you. However, we may withhold some personal information where the risk to you or our business is too great to disclose the information. 

b. Right to request deletion of your personal information

You may also request that we delete any personal information that we collected from, such as if you have been a customer of ours.  (Note that this is different from your right to “opt out” of us selling your personal information, which is described below; also note that we do not generally collect personal information directly from consumers.)  However, we may retain personal information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.  Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

c. Right to Opt-out of the sale of your personal information.

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” – including in the definition making available a wide variety of information in exchange for “valuable consideration.” 

Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the above table in Section 2 of this Addendum.

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

d. How to exercise your access and (if applicable) deletion rights

California residents may exercise their California privacy rights by sending an email to privacy@webbula.com, submitting your request to our Privacy Center, or by contacting us at 888-993-2285 ext 4 . 

For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights.  For instance, if you request categories or specific pieces of personal information we have received about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.  

Once we have verified your identity, we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories. 
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so.   
  • Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an “opt out” or a “deletion”:  because “opt out” or “do not sell” rights enable us to maintain your information for “suppression” purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting “deletion” actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences.  (In addition, “deletion” rights only apply to information that we have collected “from” consumers – which does not apply to much of the information in our databases.)  
  • Upon completion of the above process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you.  Certain information may be exempt from such requests under applicable law.  

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

e. Right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

f. Information About Persons Under 16 Years of Age

We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent). 

g. Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney. 

Last Modified:  January 2, 2020