YOUR CALIFORNIA PRIVACY RIGHTS

Effective as of December 17, 2019

This California Privacy Notice (“Notice”) supplements the information contained in the Fraudlogix, Inc., and its subsidiaries (collectively, “we,” “us,” or “our”) Privacy Policy effective May 16, 2018 (https://www.fraudlogix.com/privacy-policy/) and applies solely to 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 Cal. Civil Code § 1798.83.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect 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 or device (“personal information”). We have collected the following categories (as listed in Cal. Civ. Code § 1798.140(o)(1)) of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

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

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.

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).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other 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, faceprints, 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.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or 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

 

Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope (such as information covered by the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, the Driver’s Privacy Protection Act of 1994, etc.).

We obtain the categories of personal information listed above from the following categories (as listed in Cal. Civ. Code § 1798.140(o)(1)) of sources:

  • Directly and indirectly from activity on our website (www.fraudlogix.com).

  • From third parties that interact with us in connection with the services we perform. For example, from our clients when they utilize our services or the Fraudlogix Pixel.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To improve our website and present its contents to you.

  • For testing, research, analysis and data security measures to detect and inform our clients of security and business risks, intelligence and analysis, along with malicious, deceptive, fraudulent, or illegal activity.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As forth in the CCPA.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:

Identifiers.

Category F:

Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our business partners.

In the preceding twelve (12) months, we have sold personal information of California residents. Under Cal. Civ. Code § 1798.120, California residents have the right to opt out of the sale of their personal information. To opt out, please contact us using the contact information at the bottom of this notice.

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.

Right to Know

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. Once we receive and confirm your verifiable consumer request, 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.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • 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.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  2. Debug products to identify and repair errors that impair existing intended functionality.

  3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  4. Comply with a legal obligation.

  5. Make other internal and lawful uses of that information.

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 also make a verifiable consumer request on behalf of your minor child.

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.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 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. You may be required to provide additional information to verify your identity and request before further action is taken.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to Our California Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us or submit a verifiable consumer request to us by either:

  • Calling us at (954) 889-7805;

  • Emailing us at privacy@fraudlogix.com; or

  • Sending correspondence to:
    Fraudlogix
    221 West Hallandale Beach Blvd., Suite 107,
    Hallandale Beach, Florida 33009 USA