Singlewire Privacy Notice for California Consumers
Effective Date: January 1, 2020
The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”). California residents who are employees, employee applicants, or contractors qualify and are included as Consumers.
Information We Collect
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, Singlewire collects the following categories of Personal Information from its Consumers, which will depend on the particular Business Purpose for which we collect it:
|Category||Examples of Personal Information Collected|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.|
|B. 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, 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.Note: Some personal information included in this category may overlap with other categories.|
|C. 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, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|E. 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.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.|
|J. Education information, as defined by the Family Educational Rights and Privacy Act||Education Records as defined by FERPA.|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Personal information does not include deidentified or aggregated consumer information.
Singlewire obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
- From third-party data sources. For example, from consumer reporting agencies when we conduct credit checks or employee background checks.
How We Use Personal Information
We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:
- Deliver our products and services to you, including providing access to our website’s online features, or engaging in other transactions with us
- Enable you to create an account to conduct transactions and otherwise interact with us
- Communicate with you about our products and services, including to respond to your customer service requests or respond to any other inquiry or correspondence you send to us
- Present you with marketing relating to our products and services, including promotions and other offers, and more relevant display advertisements
- Provide you updates, reminders, or other informational content
- Enable you to participate in a sales promotion or survey
- Enable you to participate in forums, blogs, and post testimonials. If you provide a testimonial, you name will be publicly posted along with the testimonial. Please remember that blogs and testimonials can be located in the public areas of our Website. Do not share content that you would not want others to read, save, or share
- If you provide your information in the context of an employment application or your employment, we will use your information to serve those purposes.
- To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, mobile applications, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business.
- For research, analysis, and business development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Singlewire assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Singlewire about our Consumers is among the assets transferred.
How We Share Personal Information
Singlewire may disclose your Personal Information to a third party for a business purpose, including to our service providers.
We share and disclose your personal information with the following categories of third parties:
- Service providers.
- Third parties with whom you direct us to share your personal information
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Singlewire has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
We may disclose your personal information for a business purpose to service providers which we contract to perform services related to our products or employee recordkeeping.
Sales of Personal Information
In the preceding twelve (12) months, Singlewire has not sold personal information.
Your Consumer Rights and Choices
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Singlewire disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, a list disclosing the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Singlewire 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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we 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, 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.
- 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.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us at [email protected] or the below address. We will verify your request using the information associated with your account or employment data, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
ATTN: Privacy Legal Dept
Singlewire Software, LLC
P.O. Box 46218
Madison, WI 53744
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
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.
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.
Changes to Our CCPA Privacy Notice
Singlewire reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the App and Website and update the notice’s Effective Date above. Your continued use of our App or Website or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Privacy Notice constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Singlewire collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at [email protected].
Version December 2019