CCPA Privacy Notice Addendum
This California section supplements the Privacy Policy and applies solely to California consumers (excluding our personnel). The Table below describes how we process California consumers’ personal information (excluding our personnel), based on definitions laid out in the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").
Categories of personal information collected over the 12-month period prior to the effective date of our Privacy Policy
Note: The categories of data below stem from a statutory list set forth under the CCPA. |
Sources of collection over the 12-month period prior to the effective date of our Privacy Policy | Categories of third parties with whom we disclosed the personal information for a business purpose over the 12-month period prior to the effective date of our Privacy Policy | Business or commercial purposes for which the personal information was collected over the 12-month period prior to the effective date of our Privacy Policy (in addition to the purposes listed in the Privacy Policy) |
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Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers |
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Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, and medical information |
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Characteristics of protected classifications under California or federal law, such as race, color, national origin, ethnicity, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status |
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Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies |
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Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements |
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Geolocation data, including precise geolocation information |
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Audio, electronic, visual, and similar information |
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Professional or employment-related information |
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Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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Contents of your messages on our services |
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- To protect the safety and security of our users, we implement a safety retention window of up to three months following account closure. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
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Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
- We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data to comply with tax and accounting legal requirements, credit card information, if any, for the duration the user may challenge the transaction. We may also need to keep “traffic data” / logs for one1 year to comply with legal data retention obligations. We also keep records of consents users give us to evidence our compliance with applicable law.
- We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download / purchase for 5five years to support our customer care decisions, enforce our rights and enable us to defend ourselves in the event of a claim, profile data for one year in anticipation of potential litigation, and for the establishment, exercise or defense of legal claims, and data necessary to prevent users who were banned or people who were found to be under the age of 18 from opening a new account, to ensure the safety and vital interests of our users.
- Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected or sold the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
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