Effective January 1, 2023
This Notice does not apply with respect to Personal Information we collect from our employees, independent contractors or job applicants. For information as to the Personal Information we collect from such individuals, click here.
We have collected the following categories of Personal Information from Consumers within the last twelve (12) months:
|Identifiers||Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Credit card, debit card, bank account number and other financial information you provide in connection with your purchase of our Services|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement|
|H. Audio, electronic, visual, thermal, olfactory or similar information||Photos or videos provided in connection with our Services, call recordings we initiate and the content of certain communications between our clients and other consumers|
|K. Inferences drawn from Personal Information||Inferences drawn from any of the information above to create a profile reflecting the Consumer’s preferences|
Personal Information does not include deidentified or aggregated consumer information.
Certain information we collect from our clients may be considered “Sensitive Personal Information” under the CCPR/CPRA, including credit card or account information and the content of certain communications between our clients and other Consumers. We collect and store such Sensitive Personal Information solely to collect payments and to provide services to our clients.
Under the CCPA / CPRA, certain transfers or sharing of Personal Information may constitute “selling” when such Personal Information is disclosed to a third party for monetary or other valuable consideration or “sharing” when such Personal Information is disclosed to a third party for purposes of targeted, or cross-contextual, advertising.
We may “sell” or “share” your Personal Information with third party digital advertising networks in order to serve you content, offers and advertising relevant to your interests. Specifically, that includes sharing Identifiers – such as your Internet Protocol address, email address and/or phone number; or Internet activity -- including your browsing history, search history and/or information as to your interaction with our websites, marketing or advertising.
Under the CCPA / CPRA, you have the right to opt-out from the sale or sharing of your Personal Information. If you would like to exercise your right to opt-out, click the Do Not Sell or Share My Personal Information button at the footer of our website.
Under the CCPA / CPRA, you have certain rights with respect to your Personal Information collected and maintained by us, including: (i) the right to access your Personal Information, (ii) the right to information about the Personal Information we have collected, (iii) the right to delete your Personal Information, and (iv) the right to correct your Personal information.
You have the right to limit the use and disclosure of your Sensitive Personal Information to the purpose of providing you with services. We only collect, use and disclose Sensitive Personal Information of Consumers for purposes of providing our services. Therefore, we are not required to provide you with the right to limit use of Sensitive Personal Information.
To exercise these rights described above, please submit a verifiable request to us by either of the following methods:
Only you or a person authorized to act on your behalf may make a verifiable request related to your Personal Information. You may also make a verifiable request on behalf of your minor child. If you are making a request as an authorized person for someone else, please provide us with information sufficient to demonstrate your authority to act on behalf of such person.
You may make a verifiable request for information access not more than twice within any 12-month period. The verifiable request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identify or authority to make the request and confirm the Personal Information related to you.
Making a verifiable request does not require you to create an account with us. However, if you have an account with us, we may require you to log-in to your account in order to verify your identify or authority to request access to or deletion of your Personal Information.
We will only use Personal Information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable request within forty-five (45) days of our receipt of the request. If we require more time (up to an additional 45 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 date our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to access your Personal Information, 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.
We store your Personal Information as reasonably necessary and proportionate to accomplish the purposes identified in this Notice and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Hibu acts as a service provider to our clients. When acting in this capacity, we process personal information on behalf of our clients and we have no direct relationship with the end-users who use our clients’ services or products or visit our clients’ websites.
For any questions or concerns about this Notice or about Hibu’s privacy practices, please contact us at Privacy.OfficerUS@hibu.com.