My California Privacy Rights

Last updated: May 13, 2020

This policy is specific and applies only to web visitors of www.proffiliates.com (the “Site”) who are California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations.

California Shine the Light

Under the “Shine the Light Law”, California residents may, no more than once per calendar year, request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes. To be valid, requests must be submitted to us at ccparequests@proffiliatesinc.com. Within thirty days of receiving this request, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of the third parties who have received such. We reserve our right not to respond to requests submitted other than to the address specified in this section.

California Consumer Privacy Act of 2018 (“CCPA”)

Under the California Consumer Privacy Act of 2018 (“CCPA”), up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. This Privacy Policy contains important information regarding our collection, disclosure, and sale of personal information practices, in addition to instructions on how to exercise your rights regarding your personal information.

What Personal Information Do We Collect?

We collect, and have collected personal information about web visitors to the Site in the preceding 12 months in the following categories:

Categories of Personal InformationCategories of Sources From Which Personal Information is CollectedBusiness or Commercial Purpose for Which Each Category Will be Used
Identifiers, or information that identifies, relates to, describes, or is capable of being associated with, a particular individualConsumer through the Site; Advertising companies and networks; and Consumer data resellers/brokers Provide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance
Characteristics of protected classifications under California or federal law Consumer through the Site; Advertising companies and networks; and Consumer data resellers/brokers Provide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance
Internet or other electronic network activity informationConsumer through the Site; Advertising companies and networks; and Consumer data resellers/brokers Provide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance
Geolocation information Consumer through the Site; Advertising companies and networks; and Consumer data resellers/brokers Provide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance
Commercial information Consumer through the Site; Advertising companies and networks; and Consumer data resellers/brokersProvide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behavior, etc. Consumer through the Site; Advertising companies and networks; and Consumer data resellers/brokers Provide you with the ability to access and interact with the Site, including the ability to leave a reply; Track consumer interaction with the Site and email communications; Fulfill requests submitted through the Site; Connect you with the particular services or products featured on the Site which you indicate a need for; Advertising/marketing services, including affiliate marketing; Personalize and improve the Site; Analytics and internal research; Internal database; Secure the Site; Customer service; and Legal compliance

We collect the above personal information directly from you, including through the use of cookies and web beacons featured on the Site, through your clicks and interactions with the Site; when you contact us through the Site; or submit reports to us through the Site. To the extent that you register and login to the Site’s online reporting center, we also collect the above personal information directly from you, including through the use of cookies and web beacons featured on the Site.

We use and store cookies on your computer to facilitate and customize your use of our Site. A cookie is a small data text file, which is stored on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Web beacons are code requiring a call back to a server to render, and which deliver information to us about your IP address and information from your browser. Cookies make your use of the Site easier, make the Site run more smoothly, and help us to maintain a secure Site. Cookies and web beacons may collect information about you, such as your internet protocol (IP) address, browser type and version, operating system, software, and platform, Internet service provider, geographic location, area code and zip code associated with your server, time zone setting, date, time, and length of your visit, referring and exit domain names and websites, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, and clickstream data.

With respect to our other online properties, to the extent that you subscribe to receive electronic communications from us through such, including but not limited to our email newsletters and alerts, we collect the above personal information directly from you through such online properties, and when you open and/or click on the related email advertisements which we send you. To the extent that you unsubscribe from receiving future email advertisements from us, we may similarly collect the above personal information to carry out your choice. We also collect information on whether you responded to a particular advertisement featured on any of our online properties, and which third party advertisements and links you click through such.

In addition to the above, we also collect personal information from advertising networks and consumer data resellers/brokers.

What Personal Information Do We Disclose?

We have disclosed personal information for a business purpose to third parties within the preceding 12 months in all of the above categories to our third party service providers we utilize to assist us in providing the Site and in connection with our services, and to support our internal and business operations, such as data processing, data storage, logging of user experiences, form population, research, analytics, web hosting, marketing, delivery of promotional or transactional materials, and retargeting.

With respect to our other online properties, we may also disclose personal information in all of the above categories to third party service providers, advertisers, lead purchasers, and lead aggregators in our network when you engage in certain activities, including, but not limited to indicating a need for a particular featured service or product, requesting or purchasing products or services offered by these third parties, electing to receive information or communications from them, or electing to participate in contests, sweepstakes, games, scholarships, or other programs sponsored or provided by these third parties, in whole or in part. We may also disclose personal information in all of the above categories to third party service providers, advertisers, lead purchasers, lead aggregators, and marketing partners in our network that are interested in contacting you or providing offers to you that may be related to our products or services or about other products or services you may find interesting, and for the purpose of tracking clicks/conversions. We also disclose personal information in all of the above categories to our third party service providers, advertisers, lead purchasers, lead aggregators, and marketing partners in our network for the purpose of tracking clicks/conversions.

If you elect to unsubscribe from receiving future email advertisements from us through any of our other online properties, or by submitting a report through the Site, we disclose your email address to our third party advertisers through a suppression file, to comply with CAN-SPAM.

In addition to the above, to the extent legally required to comply with applicable laws and regulations, or to respond to a lawful request, or to otherwise protect our rights, we may also disclose personal information in all of the above categories to the requesting governmental agency, entity, or person. As we continue to develop our business, we might sell or buy assets. In such transactions, personal information collected through the Site may be one of the transferred business assets. In the event that we, or substantially all of our assets, are acquired, such personal information will be included within the transferred assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

What Personal Information Do We Sell?

The information collected through this Site may be combined with information collected through our other online properties. We may disclose for a business purpose and sell personal information in all of the above categories collected through our other online properties, with our third party advertisers and marketing partners.

Also, in the event that we, or substantially all of our assets, are acquired, such personal information may be included within the transferred assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

We do not have any actual knowledge of the sale of personal information of minors under 16 years of age. There are no financial incentives to disclose.

Your Right to Request to Know and How to Submit a Verified Request to Know

A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following from us:

  1. specific pieces of personal information that we have collected about you;
  2. categories of personal information that we have collected about you;
  3. categories of sources from which the personal information was collected;
  4. categories of personal information that we have sold or disclosed for a business purpose about you;
  5. categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  6. the business or commercial purpose for collecting or selling personal information.
The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.

To submit a request to know, please click here, or email us at ccparequests@proffiliatesinc.com. To process your request, we may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.

Your Right to Request Deletion and How to Submit a Verified Request to Delete

You have the right to request the deletion of any personal information which we have collected about you, or which we maintain. To submit a verifiable request to delete, please click here, or email your request to ccparequests@proffiliatesinc.com. To process your request, we may require that you submit the following information in conjunction with your request: your first name, last name, a California address, and email address. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for deletion, we may require the following before processing the request: 1) provide proof of your written and signed permission with the authorized agent to act on your behalf; 2) directly verify your own identity with us; and 3) directly confirm with us that you provided the authorized agent permission to submit the request on your behalf. The information which you submit in conjunction with your request to delete will be used for the express purposes of verification and providing you with responsive information to your request, if required.

We utilize a two-step process for online requests to delete, whereby you first submit your request to delete, and second, you separately confirm that you want your personal information deleted.

To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.

Your Right to Non-Discrimination for the Exercise of Your Privacy Rights

California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. However, a business may offer a financial incentive or price or service difference if it is reasonably related to the value of the consumer’s data. A business shall notify consumers of any financial incentive or price or service difference.

Our General Privacy Policy

Our general privacy policy is located here

Updates

We will revise this notice from time to time as implementing regulations further develop and come into effect and we are able to provide you with better information on your CCPA rights and how to exercise them. Need More Information or Having Difficulty Accessing this Information? If you have any questions or concerns regarding your California privacy rights, or our privacy practices, please email privacy@proffiliatesinc.com, or contact us by mail at 50 California Street, Suite 1500, San Francisco, CA 94111. Further, if you have a disability which interferes with your ability to access this policy, accommodations can be made to present the policy in an alternative format, to assist you. If you would like to receive this information in another format that is accessible to your needs (for example: audio, large print, etc.) please contact us.

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