Privacy Notice For California Residents Under The California Consumer Privacy Act
Last updated: September 23, 2021
This privacy notice (“Privacy Notice”) for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) supplements the information contained in our standard Privacy Policy and applies solely to residents of the State of California as defined under the CCPA. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Further, this Privacy Notice is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.
As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Recently Updated” heading located at the top of the Privacy Notice.
TYPES OF PERSONAL INFORMATION WE COLLECT
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and may have collected within the last 12 months), are detailed in the table below.
Please note that, under the CCPA Personal Information does not include: publicly available information from government records and deidentified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. | Yes |
| Social Security number, driver's license number, passport number, or other similar identifiers. | No | |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Some personal information included in this category may overlap with other categories: name, signature, address, telephone number, education, employment. | Yes |
| Some personal information included in this category may overlap with other categories: Social Security number, physical characteristics or description, passport number, driver's license or state identification card number, insurance policy number, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | No | |
| C. Protected classification characteristics under California or federal law. | Citizenship, marital status, sex (including gender, gender identity) | Yes |
| Age (40 years or older), race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | No | |
| D. Commercial information. | Records of personal property, personal products or services purchased, obtained, or considered, or other personal purchasing or consuming histories or tendencies. | No |
| 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, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity. | Information on a consumer's interaction with SmartBreast website, application, or advertisement. | Yes |
| Browsing history, search history. | No | |
| G. Geolocation data. | Physical location. | Yes, only when interacting with SmartBreast website or application. |
| Physical location or movements. | No, except above. | |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Job history. | Yes, if revealed publicly (e.g., LinkedIn) |
| Job performance evaluations. | No | |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No |
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect some of the above detailed information from you, as follows: (i) directly from you, for example, if you contact us or browse our websites; (ii) from third-party business partners such as analytics providers.
USE OF PERSONAL INFORMATION
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
- To provide, support, personalize, and develop our website and Services, as well as improve our Services.
- For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Services.
- For testing, research, analysis, and product development, including to develop and improve our 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.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING DATA
We may disclose your Personal Information to a third party for a business purpose.
We share your Personal Information with the following categories of third parties:
- Service providers – Such as our internet servers’ providers.
- Data aggregators – For analytic purposes.
- Partners – for performing our Business.
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
In the preceding twelve (12) months, the Company has disclosed the following category of Personal Information for a business purpose:
Category A: Identifiers.
Category B: Personal information categories listed in the California Customer Records statute
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity
Category G: Geolocation data.
Category I: Professional or employment-related information.
SALES OF PERSONAL INFORMATION
In the preceding twelve (12) months, Company has not sold Personal Information. Note that we are considered as the Service Provider of our Business Partners. Thus, in the event you are an end user interacting with a Business Partner’s App, the Business Partner may provide you with a “Do Not Sell” link. You may also use industry opt-out mechanisms such as disabling cookies on your browser.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA provides Consumers with specific rights regarding their Personal Information. Please review our Privacy Rights Policy regarding your rights under applicable law. You may exercise any or all of your above rights in relation to your Personal Information by filling out the Data Subject Request (“DSR”) form and send it to: [email protected].
Contact Us
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at: [email protected].