Privacy Notice for California Residents
Last Updated: January 27, 2020
If you have a disability, you may access this Privacy Notice in an alternative format by contacting our Privacy Team.
Personal Information We Collect
In the preceding twelve (12) months, we have collected the following categories of Personal Information:
|Category of Personal Information Collected||Personal Information Collected||Sources of Personal Information|
|(A) Identifiers||Full name, email address, phone number, IP address, account name, MAC, UDID||Directly from consumers upon subscription.|
Directly from consumer’s activity on our Site by cookies or other tracking technologies.
Directly from consumers using our Emailing Service (re their contact list)
From third parties that interact with
|(F) Internet or Other Electronic Network Activity Information||Interaction with our Site use of our service over the internet||Directly from consumer’s device by using cookies or other tracking technologies.|
|(F) Geolocation Data||Physical address</p?||Directly from consumers by using IP address, or as made available on publicly available sources.|
Sharing Personal Information
We disclose your Personal Information to third parties for a business purpose (as it is defined under the CCPA). When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Information confidential and not use it for any purpose except in the performance of the contract.
In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Information with the following categories of recipients for a business purpose:
- Service Providers;
Selling Personal Information
In the preceding twelve (12) months, we may have sold the following categories of Personal Information to third parties or businesses for commercial purposes:
Rights under the CCPA
Access to Personal Information
You may request that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.
You have the right to request that we delete any Personal Information collected from you and retained unless retaining the information is necessary for us or for our service providers 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.
- Debug products to identify and repair errors that impair existing or 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).
- 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.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors and consultants to delete) your Personal Information, unless an exception applies.
Right to opt-out
You have the right, at any time, to direct us not to sell your personal information to third parties, as defined under the CCPA. This is also referred to as your right to opt-out.
You have the right to opt-out of sales, within the meaning of the CCPA, of certain information subject to the CCPA. You are not required to have an account with us to exercise your right to opt-out of the sale of your personal information to third parties. Please submit your request to our Privacy Team or online, by visiting the following link: “DO NOT SELL MY PERSONAL INFORMATION“.
Our Site and Services are meant for adults. We do not knowingly collect personally identifiable information from children under 13. If you are 16 years of age or older, under the CCPA, you have the right to direct us to not sell your personal information any time (the right to opt-out). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the right to opt-in) from either the consumer, who is between 13 and 16 years old or the parent or legal guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time, as described above.
Exercising your rights
You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to our Privacy Team.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.
The request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient details to allow 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. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Information that we collect about you and how we use it, please contact our Privacy Team.
Response timing and format
Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the 45 days period. If you are a User or Customer, we will deliver our written response to you through your Customer account. If you are a Site visitor, we will deliver our response by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.
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.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code §§ 4000–4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
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.
- Deny your 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.
We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year, as applicable to the time period in which the CCPA was in effect. As of the date of publishing this Privacy Notice, such data has yet to have been received. Once such data is received, it will be published on a dedicated Consumer Requests Metrics page which will be available within this Privacy Notice.
Changes To This Policy
Lusha reserves the right to modify this Privacy Notice from time to time so please review it regularly. If we make material changes to this policy, we will notify you here, by email or by means of a notice on the Site’s homepage prior to the changes becoming effective.
Lusha Systems Inc
1177 Avenue of the Americas, 5th Floor
New York, NY 10036