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Supplemental CCPA Privacy Policy for California Residents

by Practical Law Data Privacy Advisor, with Kenneth K. Dort, Drinker Biddle & Reath LLP

Related Content

Maintained • California, USA (National/Federal)


A model website privacy policy or supplemental privacy policy for use by organizations that collect, store, use, share, sell, or disclose the personal information of California residents. This California-specific notice addresses requirements from the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. This Standard Document has integrated notes with important explanations and drafting tips.

Note: On November 3, 2020, California voters approved the California Privacy Rights Act of 2020 (Proposition 24) (CPRA), which will amend and expand the CCPA on January 1, 2023. The CCPA remains in effect until the CPRA's operative date. For more on the CPRA, see Article, Expert Q&A: The California Privacy Rights Act of 2020 (CPRA).

Note: Read This Before Using Document

[COMPANY] Privacy Policy for California Residents

Effective Date: [DATE]

Last [Updated/Reviewed] on: [DATE]

This Privacy Policy for California Residents supplements the information contained in [COMPANY]'s [HYPERLINKED URL TO GENERAL PRIVACY POLICY] and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

[This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see [HYPERLINKED URL TO CALIFORNIA EMPLOYEE PRIVACY POLICY]).]

[Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.]

Note: Introduction

Information We Collect
[Our
 Website collects/We collect] information that identifies, relates to, 
describes, references, is reasonably capable of being associated with, 
or could reasonably be linked, directly or indirectly, with a particular
 consumer, household, or device ("personal information"). Personal information does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • [Information excluded from the CCPA's scope, like:
    • health
       or medical information covered by the Health Insurance Portability and 
      Accountability Act of 1996 (HIPAA) and the California Confidentiality of
       Medical Information Act (CMIA), clinical trial data, or other 
      qualifying research data;
    • personal
       information covered by certain sector-specific privacy laws, including 
      the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) 
      or California Financial Information Privacy Act (FIPA), and the Driver's
       Privacy Protection Act of 1994.]

      Note: Personal Information Definition and Exceptions

In
 particular, [our Website has/we have] collected the following 
categories of personal information from consumers within the last twelve
 (12) months: 
Category
Examples
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, passport number, or 
other similar identifiers.
[YES/NO]
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, passport 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.
Some personal information included in this category may overlap with other categories.
[YES/NO]
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).
[YES/NO]
D. Commercial information.
Records
 of personal property, products or services purchased, obtained, or 
considered, or other purchasing or consuming histories or tendencies.
[YES/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, faceprints, and voiceprints, iris or
 retina scans, keystroke, gait, or other physical patterns, and sleep, 
health, or exercise data.
[YES/NO]
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
[YES/NO]
G. Geolocation data.
Physical location or movements. 
[YES/NO]
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
[YES/NO]
I. Professional or employment-related information.
Current or past job history or performance evaluations.
[YES/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. 
[YES/NO]
K. Inferences drawn from other personal information.
Profile
 reflecting a person's preferences, characteristics, psychological 
trends, predispositions, behavior, attitudes, intelligence, abilities, 
and aptitudes.
[YES/NO]

Note: Personal Information Categories

[Our Website obtains/We obtain] 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.]

  • [[OTHER SOURCE CATEGORY].]

    Note: Source Category Identification

Use of Personal Information
We may use, [sell,] or disclose the personal information we collect for one or more of the following purposes: 
  • To
     fulfill or meet the reason you provided the information. For example, 
    if you share your name and contact information to request a price quote 
    or ask a question about our products or services, we will use that 
    personal information to respond to your inquiry. If you provide your 
    personal information to purchase a product or service, we will use that 
    information to process your payment and facilitate delivery. We may also
     save your information to facilitate new product orders or process 
    returns. 
  • [To provide, support, personalize, and develop our Website, products, and services.]
  • [To create, maintain, customize, and secure your account with us.]
  • [To process your requests, purchases, transactions, and payments and prevent transactional fraud.]
  • [To
     provide you with support and to respond to your inquiries, including to
     investigate and address your concerns and monitor and improve our 
    responses.]
  • [To
     personalize your Website experience and to deliver content and product 
    and service offerings relevant to your interests, including targeted 
    offers and ads through our Website, 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 Website, 
    products and services, databases and other technology assets, and 
    business.]
  • [For
     testing, research, analysis, and product 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.
  • [[OTHER PURPOSES].]
  • 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, in which personal information held 
    by us about our [Website users/consumers] is among the assets 
    transferred.
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.

Note: Use of Personal Information

Sharing Personal Information
We
 may share your personal information by disclosing it to a third party 
for a business purpose. We only make these business purpose disclosures 
under written contracts that describe the purposes, require the 
recipient to keep the personal information confidential, and prohibit 
using the disclosed information for any purpose except performing the 
contract. In the preceding twelve (12) months, Company [has/ has not] 
disclosed personal information for a business purpose[ to the categories
 of third parties indicated in the chart below].
[We
 do not sell personal information./We may also share your personal 
information by selling it to third parties, subject to your right to 
opt-out of those sales. Our personal information sales [do/do not] 
include information about individuals we know are under age 16.] In the 
preceding twelve (12) months, Company [has not sold/has sold the 
following categories of] personal information[ to the categories of 
third parties indicated in the chart below]. For more on your personal 
information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Personal Information Category
Category of Third-Party Recipients
Business Purpose Disclosures
Sales
A: Identifiers.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
B: California Customer Records personal information categories.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
C: Protected classification characteristics under California or federal law.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
D: Commercial information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
E: Biometric information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
F: Internet or other similar network activity.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
G: Geolocation data.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
H: Sensory data.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
I: Professional or employment-related information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
J: Non-public education information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
K: Inferences drawn from other personal information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]

Note: Sharing Personal Information

[Reselling Personal Information]
[The
 CCPA prohibits a third party from reselling personal information unless
 you have received explicit notice and an opportunity to opt-out of 
further sales. The following businesses purchase personal information 
from us and may resell that information. To opt-out of those sales, 
please [visit that business's opt-out notice at link provided 
below/[OTHER INSTRUCTIONS]].
[Deidentified Patient Information]
[We
 [do/do not ][sell ][and/or ][disclose] deidentified patient information
 exempt from the CCPA to third parties. [To deidentify the patient 
information, we followed [the HIPAA expert determination method] 
[and/or/,] [the HIPAA safe harbor method] [and/or] [OTHER METHOD 
DESCRIPTION].]]

Note: Deidentified Patient Information

Your Rights and Choices 
The
 CCPA provides consumers (California residents) with specific rights 
regarding their personal information. This section describes your CCPA 
rights and explains how to exercise those rights.

Note: Your Rights and Choices

Right to Know and Data Portability
You
 have the right to request that we disclose certain information to you 
about our collection and use of your personal information over the past 
12 months (the "right to know"). Once we receive your request and 
confirm your identity (see Exercising Your Rights to Know or Delete), 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 or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and 
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
  • The specific pieces of personal information we collected about you (also called a data portability request).
 [We do not provide a right to know or data portability disclosure for B2B personal information.]

Note: Right to Know and Data Portability

Right to Delete 
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 (the "right to delete"). Once we receive your request and 
confirm your identity (see Exercising Your Rights to Know or Delete),
 we will review your request to see if an exception allowing us to 
retain the information 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 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.
We
 will delete or deidentify personal information not subject to one of 
these exceptions from our records and will direct our service providers 
to take similar action. 
[We do not provide these deletion rights for B2B personal information.]

Note: Deletion Request Rights

Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either: 
  • [Calling us at [TOLL-FREE NUMBER].]
  • [Emailing us at [EMAIL ADDRESS].]
  • [Visiting [WEBSITE ADDRESS].]
  • [[PASSWORD PROTECTED ACCOUNT INSTRUCTIONS].]
  • [[OTHER METHOD].] 
Only
 you, or someone legally authorized to act on your behalf, may make a 
request to know or delete related to your personal information. [To 
designate an authorized agent, [INSTRUCTIONS].] 
You may also make a request to know or delete on behalf of your child by [INSTRUCTIONS]. 
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
  • Provide
     sufficient information that allows us to reasonably verify you are the 
    person about whom we collected personal information or an authorized 
    representative, which may include:
    • [VERIFICATION REQUIREMENTS].
    • [[PARENT OR GUARDIAN VERIFICATION REQUIREMENTS].]
  • 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. 
You
 do not need to create an account with us to submit a request to know or
 delete. [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 the request to verify the requestor's identity or authority to make it. 
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Note: Exercising Your Rights to Know or Delete

Response Timing and Format
We
 will confirm receipt of your request within ten (10) business days. If 
you do not receive confirmation within the 10-day timeframe, please 
[contact [CONTACT]/[OTHER ACTION]].
We
 endeavor to substantively respond to a verifiable consumer request 
within forty-five (45) days of its receipt. If we require more time (up 
to another 45 days), we will inform you of the reason and extension 
period in writing.
If
 you have an account with us, we will deliver our written response to 
that account. If you do not have an account with us, 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 
our receipt of your request. 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[, 
specifically [EXPECTED FORMAT DESCRIPTION]].
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. 

Note: Response Timing and Format

Personal Information Sales Opt-Out and Opt-In Rights
If
 you are age 16 or older, you have the right to direct us to not sell 
your personal information at any time (the "right to opt-out"). We do 
not sell the personal information of consumers we actually know are less
 than 16 years old[, unless we receive affirmative authorization (the 
"right to opt-in") from either the consumer who is between 13 and 15 
years old, or the parent or guardian of a consumer less than 13 years 
old]. Consumers who opt-in to personal information sales may opt-out of 
future sales at any time. 
To
 exercise the right to opt-out, you (or your authorized representative) 
may submit a request to us by visiting the following Internet Web page 
link: 
[ 
Image 1 within CCPA Privacy Policy for California Residents
 ] 
[HYPERLINKED URL with the title "Do Not Sell My Personal Information"]
Once
 you make an opt-out request, we will wait at least twelve (12) months 
before asking you to reauthorize personal information sales. However, 
you may change your mind and opt back in to personal information sales 
at any time by:
[OPT-IN INSTRUCTIONS OR URL LINK]
You
 do not need to create an account with us to exercise your opt-out 
rights. We will only use personal information provided in an opt-out 
request to review and comply with the request. 

Note: Personal Information Sales Opt-Out and Opt-In Rights

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge
     you different prices or rates for goods or services, including through 
    granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest
     that you may receive a different price or rate for goods or services or
     a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in
 different prices, rates, or quality levels. Any CCPA-permitted 
financial incentive we offer will reasonably relate to your personal 
information's value and contain written terms that describe the 
program's material aspects. Participation in a financial incentive 
program requires your prior opt-in consent, which you may revoke at any 
time. [We currently provide the following financial incentives: 
[FINANCIAL INCENTIVE NAME, HYPERLINKED TO THE DISCLOSURE DOCUMENT]]  

Note: Non-Discrimination

[CCPA Rights Request Metrics]
[Metrics
 regarding the consumer rights requests we received from [all 
individuals/California residents] from January 1, [YEAR] to December 31,
 [YEAR] appear in the following chart:
Request Type
Received
Granted (in whole or in part)
Denied
[Median/Mean] Days to Respond
Requests to Know
[NUMBER]
[NUMBER]
[[TOTAL NUMBER]
OR
Unverifiable: [NUMBER].
Not by a [consumer/ California resident]: [NUMBER].
Called for information exempt from disclosure: [NUMBER].
Denied on other grounds: [NUMBER].]
[DAYS]
Requests to Delete
[NUMBER]
[NUMBER]
[[TOTAL NUMBER]
OR
Unverifiable: [NUMBER].
Not by a consumer: [NUMBER].
Called for information exempt from disclosure: [NUMBER].
Denied on other grounds: [NUMBER].]
[DAYS]
Requests to Opt-Out of Personal Information Sales
[NUMBER]
[NUMBER]
[[TOTAL NUMBER]
OR
Unverifiable: [NUMBER].
Not by a consumer: [NUMBER].
Called for information exempt from disclosure: [NUMBER].
Denied on other grounds: [NUMBER].]
[DAYS]

]

Note: CCPA Rights Request Metrics

[Other California Privacy Rights]
[California's
 "Shine the Light" law (Civil Code Section § 1798.83) permits users of 
our Website that are California residents to request certain information
 regarding our disclosure of personal information to third parties for 
their direct marketing purposes. To make such a request, please send an 
email to [EMAIL ADDRESS][ or write us at: [MAILING ADDRESS]].]

Note: Other California Privacy Rights

Changes to Our Privacy Policy
We
 reserve the right to amend this privacy policy at our discretion and at
 any time. When we make changes to this privacy policy, we will post the
 updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Note: Changes to Our Privacy Policy

Contact Information
If
 you have any questions or comments about this notice, the ways in which
 [COMPANY] collects and uses your information described here [and in the
 Privacy Policy], 
your choices and rights regarding such use, or wish to exercise your 
rights under California law, please do not hesitate to contact us at:
Phone: [TOLL-FREE PHONE NUMBER]
Website: [WEBSITE CONTACT URL]
Email: [EMAIL ADDRESS]
Postal Address: 
[COMPANY]
Attn: [CONTACT NAME/DEPARTMENT]
[PHYSICAL ADDRESS]
[[OTHER CONTACT METHOD]: [CONTACT INSTRUCTIONS]]
If
 you need to access this Policy in an alternative format due to having a
 disability, please contact [COMPANY EMAIL ADDRESS] [and] [COMPANY PHONE
 NUMBER].

Note: Contact Information

End of Document

Resource ID w-017-8754Document Type Standard documents

Products

PL US Sector Media & Entertainment, PLC US Intellectual Property and Technology, PLC US Law Department

Resource History

Changes Made to This Resource

This resource is continually monitored and revised for any necessary changes due to legal, market, or practice developments. Any significant developments affecting this resource will be described below.

  1. Office of Administrative Law Approves Amendments to CCPA Regulations

    We added Drafting Note, Uniform Opt-Out Icon and updated Drafting Note, Read This Before Using Document, Drafting Note, Verifying Consumer Identities, Personal Information Sales Opt-Out and Opt-In Rights and Drafting Note, Personal Information Sales Opt-Out and Opt-In Rights to reflect the California Office of Administrative Law's approval of modifications to the CCPA Regulations on March 15, 2021, which took immediate effect.

  2. December 2020 Proposed Modifications to CCPA Regulations

    We updated Drafting Note, Read This Before Using Document to reflect the California Attorney General's fourth…

More

© 2021 Thomson Reuters. No claim to original U.S. Government Works.

Top





 
 
 

 

                                  General Privacy Policy

Introduction
Natural TV Corporation/ NaturalTV.Com ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy
 describes the types of information we may collect from you or that you 
may provide when you visit the website NaturalTV.Com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • [Through
     mobile and desktop applications you download from this Website, which 
    provide dedicated non-browser-based interaction between you and this 
    Website.]
  • [When
     you interact with our advertising and applications on third-party 
    websites and services, if those applications or advertising include 
    links to this policy.]
It does not apply to information collected by:
  • Us
     offline or through any other means, including on any other website 
    operated by Company or any third party[ (including our affiliates and 
    subsidiaries)]; or 
  • Any
     third party [(including our affiliates and subsidiaries)], including 
    through any application or content (including advertising) that may link
     to or be accessible from [or on] the Website]
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Note: Introduction

Children Under the Age of [13/16]
Our
 Website is not intended for children under [13/16] years of age. No one
 under age [13/16] may provide any [personal] information to [or on] the
 Website. We do not knowingly collect personal information from children
 under [13/16]. If you are under [13/16], do not use or provide any 
information on this Website [or] [through any of its features,] 
[register on the Website,] [make any purchases through the Website,] 
[use any of the interactive or public comment features of this Website,]
 [or provide any information about yourself to us, including your name, 
address, telephone number, email address, or any screen name or user 
name you may use]. If we learn we have collected or received personal 
information from a child under [13/16] without verification of parental 
consent, we will delete that information. If you believe we might have 
any information from or about a child under [13/16], please contact us 
at [CONTACT INFORMATION].
[California
 residents under 16 years of age may have additional rights regarding 
the collection and sale of their personal information. Please see [Your California Privacy Rights] for more information.]

Note: Children Under the Age of 13 or 16

Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
  • By
     which you may be personally identified, such as name, postal address, 
    e-mail address, telephone number,[ social security number][ or [OTHER 
    PERSONAL INFORMATION COLLECTED]/any other identifier by which you may be
     contacted online or offline] ("personal information");
  • That is about you but individually does not identify you, such as [INFORMATION EXAMPLES]; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
  • Directly from you when you provide it to us.
  • Automatically
     as you navigate through the site. Information collected automatically 
    may include usage details, IP addresses, and information collected 
    through cookies[, web beacons,] [and other tracking technologies].
  • [From third parties, for example, our business partners.]

    Note: Information We Collect About You and How We Collect It

Information You Provide to Us

The information we collect on or through our Website may include:
  • Information
     that you provide by filling in forms on our Website. This includes 
    information provided at the time of [registering to use our Website,] 
    [subscribing to our service,] [posting material,] [or requesting further
     services]. We may also ask you for information [when you enter a 
    contest or promotion sponsored by us, and] when you report a problem 
    with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • [Your responses to surveys that we might ask you to complete for research purposes.]
  • [Details
     of transactions you carry out through our Website and of the 
    fulfillment of your orders. You may be required to provide financial 
    information before placing an order through our Website.]
  • [Your search queries on the Website.]
  • [DESCRIBE ANY OTHER TYPES OF INFORMATION THE USER PROVIDES]
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions").
 Your User Contributions are posted on and transmitted to others at your
 own risk. Although [we limit access to certain pages/you may set 
certain privacy 
settings for such information by logging into your account profile], 
please be aware that no security measures are perfect or impenetrable. 
Additionally, we cannot control the actions of other users of the 
Website with whom you may choose to share your User Contributions. 
Therefore, we cannot and do not guarantee that your User Contributions 
will not be viewed by unauthorized persons.

Note: Information You Provide to Us

Information We Collect Through Automatic Data Collection Technologies

As
 you navigate through and interact with our Website, we may use 
automatic data collection technologies to collect certain information 
about your equipment, browsing actions, and patterns, including:
  •  Details of your visits to our Website, including [traffic data,] 
    [location data,] [logs,] and other communication data and the resources 
    that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
[We
 also may use these technologies to collect information about your 
online activities over time and across third-party websites or other 
online services (behavioral tracking). Click here [INCLUDE AS LINK TO DO
 NOT TRACK DISCLOSURES] for information on how you can opt out of 
behavioral tracking on this website and how we respond to web browser 
signals and other mechanisms that enable consumers to exercise choice 
about behavioral tracking.]
The
 information we collect automatically [does/may/is only statistical data
 and does not] include personal information[, [but/or] we may maintain 
it or associate it with personal information we collect in other ways or
 receive from third parties]. It helps us to improve our Website and to 
deliver a better and more personalized service, including by enabling us
 to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
  • Cookies (or browser cookies).
     A cookie is a small file placed on the hard drive of your computer. You
     may refuse to accept browser cookies by activating the appropriate 
    setting on your browser. However, if you select this setting you may be 
    unable to access certain parts of our Website. Unless you have adjusted 
    your browser setting so that it will refuse cookies, our system will 
    issue cookies when you direct your browser to our Website. 
  • Flash Cookies.
     Certain features of our Website may use local stored objects (or Flash 
    cookies) to collect and store information about your preferences and 
    navigation to, from, and on our Website. Flash cookies are not managed 
    by the same browser settings as are used for browser cookies. For 
    information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons.
     Pages of our the Website [and our e-mails] may contain small electronic
     files known as web beacons (also referred to as clear gifs, pixel tags,
     and single-pixel gifs) that permit the Company, for example, to count 
    users who have visited those pages or [opened an email] and for other 
    related website statistics (for example, recording the popularity of 
    certain website content and verifying system and server integrity). 
[We
 do not collect personal information automatically, but we may tie this 
information to personal information about you that we collect from other
 sources or you provide to us.]

Note: Information We Collect Through Automatic Data Collection Technologies

[Third-Party Use of Cookies [and Other Tracking Technologies]]
[Some
 content or applications, including advertisements, on the Website are 
served by third-parties, including advertisers, ad networks and servers,
 content providers, and application providers. These third parties may 
use cookies [alone or in conjunction with web beacons or other tracking 
technologies] to collect information about you when you use our website.
 The information they collect may be associated with your personal 
information or they may collect information, including personal 
information, about your online activities over time and across different
 websites and other online services. They may use this information to 
provide you with interest-based (behavioral) advertising or other 
targeted content. 
We
 do not control these third parties' tracking technologies or how they 
may be used. If you have any questions about an advertisement or other 
targeted content, you should contact the responsible provider directly. 
For information about how you can opt out of receiving targeted 
advertising from many providers, see Choices About How We Use and Disclose Your Information.]

Note: Third-Party Use of Cookies [and Other Tracking Technologies]

How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • [To provide you with notices about your [account/subscription], including expiration and renewal notices.]
  • To
     carry out our obligations and enforce our rights arising from any 
    contracts entered into between you and us, including for billing and 
    collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • [To allow you to participate in interactive features on our Website.]
  • [DESCRIBE ANY OTHER USES]
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
[We
 may also use your information to contact you about [our own and 
third-parties'] goods and services that may be of interest to you. If 
you do not want us to use your information in this way, please [check 
the relevant box located on the form on which we collect your data (the 
[order form/registration form])/adjust your user preferences in your 
account profile.] For more information, see Choices About How We Use and Disclose Your Information.
We
 may use the information we have collected from you to enable us to 
display advertisements to our advertisers' target audiences. Even though
 we do not disclose your personal information for these purposes without
 your consent, if you click on or otherwise interact with an 
advertisement, the advertiser may assume that you meet its target 
criteria.]

Note: How We Use Your Information

Disclosure of Your Information
We
 may disclose aggregated information about our users[, and information 
that does not identify any individual,] without restriction. 
We may disclose personal information that we collect or you provide as described in this privacy policy:
  • To our subsidiaries and affiliates.
  • To
     contractors, service providers, and other third parties we use to 
    support our business[ and who are bound by contractual obligations to 
    keep personal information confidential and use it only for the purposes 
    for which we disclose it to them].
  • To
     a buyer or other successor in the event of a merger, divestiture, 
    restructuring, reorganization, dissolution, or other sale or transfer of
     some or all of [COMPANY NAME]'s assets, whether as a going concern or 
    as part of bankruptcy, liquidation, or similar proceeding, in which 
    personal information held by [COMPANY NAME] about our Website users is 
    among the assets transferred.
  • [To
     third parties to market their products or services to you if you have 
    [consented to/not opted out of] these disclosures. [We contractually 
    require these third parties to keep personal information confidential 
    and use it only for the purposes for which we disclose it to them.] For 
    more information, see Choices About How We Use and Disclose Your Information].
  • To
     fulfill the purpose for which you provide it. [For example, if you give
     us an email address to use the "email a friend" feature of our Website,
     we will transmit the contents of that email and your email address to 
    the recipients.]
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • [ANY OTHER TYPES OF THIRD-PARTY DISCLOSURES.]
We may also disclose your personal information:
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To
     enforce or apply our terms of use [INSERT AS LINK TO WEBSITE'S TERMS OF
     USE] [or terms of sale [INSERT AS LINK TO WEBSITE'S TERMS OF SALE OF 
    GOODS AND/OR SERVICES]] and other agreements, including for billing and 
    collection purposes.
  • If
     we believe disclosure is necessary or appropriate to protect the 
    rights, property, or safety of [COMPANY NAME], our customers, or others.
     [This includes exchanging information with other companies and 
    organizations for the purposes of fraud protection and credit risk 
    reduction.]

    Note: Disclosure of Your Information

Choices About How We Use and Disclose Your Information
We
 strive to provide you with choices regarding the personal information 
you provide to us. We have created mechanisms to provide you with the 
following control over your information: 
  • Tracking Technologies and Advertising.
     You can set your browser to refuse all or some browser cookies, or to 
    alert you when cookies are being sent. [To learn how you can manage your
     Flash cookie settings, visit the Flash player settings page on Adobe's website.] If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • [Disclosure of Your Information for Third-Party Advertising.
     If you do not want us to share your personal information with 
    unaffiliated or non-agent third parties for promotional purposes, you 
    can opt-out by [checking the relevant box located on the form on which 
    we collect your data (the [order form/registration form])/[OTHER OPT-OUT
     METHOD]]. You can also always opt-out by [logging into the Website and 
    adjusting your user preferences in your account profile][,][ checking or
     unchecking the relevant boxes] [or by] sending us an email with your 
    request to [EMAIL ADDRESS].] 
  • [Promotional Offers from the Company.
     If you do not wish to have your [email address/contact information] 
    used by the Company to promote our own or third parties' products or 
    services, you can opt-out by [[checking the relevant box located on the 
    form on which we collect your data (the [order form/registration 
    form])/[OTHER OPT-OUT METHOD]] or at any other time by] [logging into 
    the Website and adjusting your user preferences in your account profile 
    by checking or unchecking the relevant boxes or by] sending us an email 
    stating your request to [EMAIL ADDRESS]. If we have sent you a 
    promotional email, you may send us a return email asking to be omitted 
    from future email distributions. [This opt out does not apply to 
    information provided to the Company as a result of a product purchase, 
    warranty registration, product service experience or other 
    transactions.]]
  • [Targeted Advertising.
     If you do not want us to use information that we collect or that you 
    provide to us to deliver advertisements according to our advertisers' 
    target-audience preferences, you can opt-out by [OPT-OUT METHOD]. [For 
    this opt-out to function, you must have your browser set to accept all 
    browser cookies.]] 
We
 do not control third parties' collection or use of your information to 
serve interest-based advertising. However these third parties may 
provide you with ways to choose not to have your information collected 
or used in this way. You can opt out of receiving targeted ads from 
members of the Network Advertising Initiative ("NAI") on the NAI's website.
[California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.]
[Nevada
 residents who wish to exercise their sale opt-out rights under Nevada 
Revised Statutes Chapter 603A may submit a request to this designated 
address: [TOLL-FREE NUMBER/EMAIL/WEBSITE URL].[However, please know we 
do not currently sell data triggering that statute's opt-out 
requirements.]]

Note: Choices About How We Use and Disclose Your Information

[Accessing and Correcting Your Information]
[[You can review and change your personal information by logging into the Website and visiting your account profile page.] 
[You
 may also send us an email at [EMAIL ADDRESS] to request access to, 
correct or delete any personal information that you have provided to us.
 We cannot delete your personal information except by also deleting your
 user account. We may not accommodate a request to change information if
 we believe the change would violate any law or legal requirement or 
cause the information to be incorrect.]
[If
 you delete your User Contributions from the Website, copies of your 
User Contributions may remain viewable in cached and archived pages, or 
might have been copied or stored by other Website users.] [Proper access
 and use of information provided on the Website, including User 
Contributions, is governed by our terms of use [URL LINK TO WEBSITE'S 
TERMS OF USE].]
[California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.]]

Note: Accessing and Correcting Your Personal Information

[Your California Privacy Rights]
[If
 you are a California resident, California law may provide you with 
additional rights regarding our use of your personal information. To 
learn more about your California privacy rights, visit [HYPERLINK TO CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS].
[California's
 "Shine the Light" law (Civil Code Section § 1798.83) permits users of 
our App that are California residents to request certain information 
regarding our disclosure of personal information to third parties for 
their direct marketing purposes. To make such a request, please send an 
email to [EMAIL ADDRESS][ or write us at: [MAILING ADDRESS]].]]

Note: Your California Privacy Rights

[Data Security]
[We
 have implemented measures designed to secure your personal information 
from accidental loss and from unauthorized access, use, alteration, and 
disclosure. [All information you provide to us is stored on our secure 
servers behind firewalls. Any payment transactions [and [OTHER 
INFORMATION]] will be encrypted [using SSL technology].] 
The
 safety and security of your information also depends on you. Where we 
have given you (or where you have chosen) a password for access to 
certain parts of our Website, you are responsible for keeping this 
password confidential. We ask you not to share your password with 
anyone. [We urge you to be careful about giving out information in 
public areas of the Website like message boards. The information you 
share in public areas may be viewed by any user of the Website.]
Unfortunately,
 the transmission of information via the internet is not completely 
secure. Although we do our best to protect your personal information, we
 cannot guarantee the security of your personal information transmitted 
to our Website. Any transmission of personal information is at your own 
risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.] 

Note: Data Security

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page [with a notice that the privacy policy
 has been updated on the Website home page]. If we make material changes
 to how we treat our users' personal information, we will notify you [by
 email to the [primary] email address specified in your account] 
[and/or] [through a notice on the Website home page]/[OTHER NOTIFICATION
 METHOD]]. The date the privacy policy
 was last revised is identified at the top of the page. You are 
responsible for ensuring we have an up-to-date active and deliverable 
email address for you, and for periodically visiting our Website and 
this privacy policy to check for any changes.

Note: Changes to Our Privacy Policy

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: 
[ADDRESS/EMAIL ADDRESS] 
[or via our toll-free number: 
[TOLL-FREE NUMBER]]
[To register a complaint or concern, please [PRIVATE DISPUTE RESOLUTION INSTRUCTIONS].]

Note: Contact Information

End of Document

Resource ID 2-501-2704Document Type Standard documents

Products

Company business operations, PL US Sector Media & Entertainment, PL US Sector Retail, PL US Sector Technology, PLC US Commercial Transactions, PLC US Intellectual Property and Technology, PLC US Law Department

Resource History

Changes Made to This Resource

This resource is continually monitored and revised for any necessary changes due to legal, market, or practice developments. Any significant developments affecting this resource will be described below.

  1. FDPIC Reverses Swiss-US Privacy Shield Adequacy Determination

    We revised section Drafting Note, EU-US or Swiss-US Privacy Shield to reflect the Federal Data Protection and Information Commissioner's (FDPIC) September 8, 2020 policy paper concluding that the Swiss-US Privacy Shield does not offer an adequate level of protection under Switzerland's Federal Act on Data Protection (FADP) and announcing its decision to remove the US from its adequate country list (in French). For more on this development, see Legal Update, Swiss DPA Finds Swiss-US Privacy Shield Offers Inadequate Data Protection.

  2. ECJ Invalidates EU-US Privacy Shield…

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