APPROVAL LLC 

Privacy Notice for California Residents

 

Effective Date: June 26, 2020

 

This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of APPROVAL LLC, a New York limited liability company  (“Company”, “we”, “us” or “our”) 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 Notice.


Information We Collect

 

Our Website collects 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”). 

 

In particular, we will collect “identifiers” of our Website visitors. Specifically, we will collect your name, email address and other information requested during the account registration process on our Website, and Internet Protocol address. Our Website obtains the personal information listed above directly from you when you register for an account on the Website or otherwise provide your information on our Website. 


Use of Personal Information

We may use the personal information we collect for one or more of the following purposes (the “Purposes”):

 

  1. To fulfill or meet the reason you provided the information. 

 

  1. For marketing purposes. Specifically, by providing any information on our Website, you consent to us using that information to contact you in connection with offers or promotions we may have in the future. However, we will not sell or share your information with third party for their own promotional purposes.

 

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

 

  1. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

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 Personal Information

We may disclose your personal information to a third party for a business purpose, such as our third-party service providers. 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. 

 

Specifically, we share (but do not sell) your personal information with the following categories of third parties:

 

  1. Service providers.

 

  1. Data aggregators.

 

  1. Social media companies.

 

  1. Internet cookie data recipients, like Google Analytics.

Sales of Personal Information

 

Your personal information is “sold” when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA. The Company will not sell your personal 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.


Access to Specific Information and Data Portability Rights

 

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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

 

  1. The categories of personal information we collected about you.

 

  1. The categories of sources for the personal information we collected about you.

 

  1. Our business or commercial purpose for collecting or selling that personal information.

 

  1. The categories of third parties with whom we share that personal information.

 

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

 

  1. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

 

  1. sales, identifying the personal information categories that each category of recipient purchased; and
  2. 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 exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

 

  1. 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.

 

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

 

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

 

  1. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

 

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

 

  1. 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.

 

  1. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

 

  1. Comply with a legal obligation.

 

  1. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

You may opt-out of or revoke any of the rights granted to us in connection with the continued collection and/or us of your personal information. To exercise the access, data portability, opt-out, revocation and deletion rights described above, please submit a verifiable consumer request to us by either: Emailing us at privacy@withapproval.com or submitting a request online at https://www.withapproval.com/contact.



Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

 

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

 

  1. 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. Making a verifiable consumer request does not require you to create an account with us. 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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.


Response Timing and Format

 

We endeavor to respond to a verifiable consumer request within forty-five (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. 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 the verifiable consumer request’s receipt. 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.

 

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.

 

Non-Discrimination

 

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

 


Changes to Our 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 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.


Contact Information

 

If you have any questions or comments about this notice, the ways in which the 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:

 

Website: https://www.withapproval.com

 

Email: privacy@withapproval.com