Effective Date of Policy: July 1, 2020
Consistent with the CCPA, job applicants, current and former employees, contractors, and subjects of certain business-to-business communications acting in their capacity as representatives of another business are not considered Consumers for the purposes of this Policy or the rights described herein.
COLLECTION AND USE OF PERSONAL INFORMATION
In addition, CPN may collect, use, and disclose your PI as required or permitted by applicable law. CPN does not treat de-identified data or aggregate consumer information as PI, and CPN reserves the right to convert, or permit others to convert, your PI into de-identified data or aggregate consumer information for business purposes.
CPN has not “Sold” (as the term “Sale” is defined by the CCPA) Consumer PI since its inception.
CALIFORNIA PRIVACY RIGHTS
Under the CCPA, California Consumers have certain rights which they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. CPN will not fulfill a CCPA request unless we have been provided sufficient information for CPN to reasonably verify the identity of the requestor and the validity of the request.
Some PI CPN maintains about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for CPN to be able to verify that it is a particular Consumer’s PI. Accordingly, CPN will not include such information in response to Consumer requests. If CPN cannot comply with a request, we will explain the reasons in the response. You are not required to create an account with CPN to make a verifiable request, but you may use your account information to do so. CPN will use PI provided in your request to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to CPN for another purpose.
Your California Consumer privacy rights are described below. To make a request, please email us at email@example.com or call us at 1-800-673-1220. We will take appropriate steps to confirm the identity of a Consumer making a request for purposes of verifying the authenticity of the request. You may be required to provide certain PI to allow us to verify that you are the Consumer about whom the request is being made. Please promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply the heightened verification standards. An authorized agent may submit a request on behalf of a Consumer if the Consumer has provided the authorized agent with power of attorney in accordance with California law. Alternatively, the agent must (1) present verifiable written authorization from the Consumer that the agent has the Consumer’s permission to submit the request; and (2) independently verify the agent’s own identity with Company.
We may collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with consumer requests to the extent that doing so would infringe on our, or any other person’s or party’s rights or conflict with applicable law.
You have the right to request that we disclose your PI that we have collected and are maintaining for the 12-month period prior to the request date.
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for collecting or selling your PI.
- The categories of third parties to whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or a statement that no such disclosure occurred.
- A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred.
You have the right to make or obtain a portable copy of your PI that we (1) have collected in the 12 months prior to the request date and (2) currently are maintaining. Please note that we retain PI for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures. To make such a request, email us at firstname.lastname@example.org
"Do Not Sell" Rights
We do not Sell California Consumer PI as those terms are defined in the CCPA. Some web browsers have options that may be characterized as “do not track” settings, which may or may not affect your settings related to our website. We do not understand them to operate in that manner or to signify a “do not sell” request made by a Consumer. We understand that various parties are developing “do not sell” signals, and we may recognize certain such signals if we conclude such a program is appropriate.
Except to the extent we have a basis for retention under the CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, retaining PI to complete transactions and provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes such as maintaining business records, to comply with law or otherwise cooperate with law enforcement, and to exercise or defend legal claims. Note also that we are not required to delete your PI that we did not collect directly from you. To make such a request, email us at email@example.com.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
“Shine the Light” Law of California
California Civil Code Section 1798.83 permits California customers to request certain information regarding our disclosure of personal information to third parties for their direct marketing or business purposes. To make such a request, please email us at firstname.lastname@example.org or write us at: CPAP Nation 29903 Agoura Rd., Suite 120, Agoura Hills, CA 91301.
Please note that “Shine the Light” rights and CCPA rights are established under different legal regimes and must be exercised separately.
For more information regarding your California privacy rights, you may contact us at 1-800-673-1220 or email us at email@example.com.