California Privacy Disclosures
Note for California Residents: Please see below for specific details on your rights under California law.
Definitions of terms used in this section
- “CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.
- “Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Site.
- “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.
- “Sensitive Personal Information” means personal information that reveals (a) consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data. In addition, “sensitive personal information” includes processing of biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
- “Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.
- “Special Categories Personal Information” has the same meaning as set forth in the GDPR, which generally includes, subject to certain exceptions, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation shall be prohibited.
- “Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.
Categories of your personal information that we may acquire
We may collect, obtain or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:
|Categories of Personal Information
|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
|Income or net worth; products or services purchased, obtained, or considered
|Internet or other electronic network activity information
|Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
|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, bank account number, or any other financial information.
Protection of your personal information
Security Measures: We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.
No Liability for Breach: Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. By using the Site, you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.
Breach Notification: If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.
Retention: We will retain your Personal Information for as long as it is reasonably useful for commercial purposes. We will retain and use your Personal Information as necessary to comply with our legal obligations or data retention policies, resolve disputes and enforce our agreements.
Your privacy rights
Rights of California Residents
The CCPA grants residents of California certain rights with respect to their Personal Information. California residents have the following rights under the CCPA:
- the right to know the categories of Personal Information we have collected about you;
- the right to know the categories of sources from which Personal Information is collected, sold or shared, and to whom;
- the right to know our business or commercial purpose for collecting, selling, or sharing your Personal Information;
- the right to know the categories of third parties to whom we business disclose your Personal Information;
- the right to request specific pieces of your Personal Information that we hold;
- the right to request the deletion of your Personal Information, subject to several exceptions;
- the right to opt out of the sale of your Personal Information;
- the right to request that we correct inaccurate Personal Information that we have about you;
- the right to request that we limit the use and disclosure of sensitive Personal Information collected about you; and
- the right to not be unlawfully discriminated against for exercising these rights.
We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.
Exercising Your Rights Under the CCPA
California residents, as well as authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at firstname.lastname@example.org or by calling us at +44(0) 20 7881 6000.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we have collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our 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 existing intended functionality.
- 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.
Consumers’ Right to Know What Personal Information is Sold or Shared and to Whom
The CCPA gives California residents the right to ask us to disclose (1) the categories of Personal Information that we collect about our consumers; (2) the categories of Personal Information that the business sold or shared about the consumer and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and (3) the categories of personal information that the business disclosed about the consumer for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
Categories of Personal Information We Disclose or Sell
In the preceding 12 months, we have not shared, disclosed, or sold Personal Information for a business purpose.
Response Timing and Procedures
We endeavor to respond to a verifiable consumer request within forty-five (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 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 request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Do Not Track
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.
Shine the Light
California's “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties' direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing Personal Information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.
Our Site is not directed to, and we do not intend to or knowingly collect or solicit Personal Information online from, children under the age of 13. If a child under 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us through the contact information provided here to request that we remove the information from our systems. If you are under the age of 13, do not provide us with any Personal Information.
Last updated: July 2023