CCPA Privacy Notice For California Consumers

Effective January 1, 2020

Hibu Inc. (“Hibu”, “we”, “us” or “our”) is providing this CCPA Privacy Notice for California Consumers (“CCPA Privacy Notice”) to notify you of our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and to explain the rights available to you under the CCPA.  This Notice applies to Personal Information that we collect from Consumers.  “Personal Information” means 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 household.  “Consumer” means a person who is a California resident. For purposes of this CCPA Privacy Notice, when we refer to “you” or “your” we mean a Consumer. 

This Notice does not apply with respect to (i) information we collect from our employees, independent contractors or job applicants; or (ii) information we collect in the course of transacting, communicating or providing services to our customers because all of our customers are business-to-business customers.  (See Exemptions below.)

 

Information We Collect

We have collected the following categories of Personal Information from Consumers within the last twelve (12) months:

 

CategoryExamplesCollected?
A. IdentifiersName, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiersYes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Name, postal address, telephone numberYes
C. Protected classification characteristics under California or federal lawAge (40 years or older), race, color, ancestry, national original, citizenship, religion or creed, marital statusNo
D. Commercial informationRecords of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesYes
E. Biometric informationGenetic, physiological, behavioral and biological characteristics, such as fingerprints, faceprints, voiceprints and facial recognitionNo
F. Internet or other similar network activityBrowsing history, search history, information on a consumer's interaction with a website, application, or advertisementYes
G. Geolocation dataPhysical location or movementsNo
H. Sensory dataAudio, electronic, visual, thermal, olfactory or similar informationNo
I. Professional or employment-related informationCurrent or past job history or performance evaluationsNo
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 recordsNo
K. Inferences drawn fromProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudesNo

 

Personal Information does not include deidentified or aggregated consumer information.

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you when you visit our website, fill in forms on our websites or submit information through our websites, including by posting reviews or other information.
  • Directly from you when you sign up for an account on our websites.
  • Indirectly from you through website usage details collected automatically, online searches you conduct or your interaction with ads that we place on websites or other media or your interaction with ads, including video ads, we send to you or make available to you.  For example, we may collect information about your use of our websites through cookies, which are information files stored on your computer that help websites remember who you are and information about your visit.   
  • Directly from you when you communicate with us, including by phone, email, text message, messaging application, social media, through our mobile applications or through other means.
  • From third-parties with whom we interact in connection with the services we perform. 
  • From your social media account.  When you use a social network login to access our services, you may share certain Personal Information from your social media account with us, for example, your name, email address, photos, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your services account.  The specific information shared depends on your security settings and the privacy policy of your social media network.
  • From third-party data providers when they share information with us.

 

Use of Personal Information

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

  • To respond to your requests for services or for information.
  • To create, maintain and customize your account with us.
  • To provide you with support and to respond to your inquires, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety and security of our websites and services and to minimize fraud.
  • To personalize your website experience by serving advertising and content tailored to your interests.  
  • To track your usage of and interaction with our websites, communications, ads, including video ads, products and services. 
  • To respond to law enforcement requests, court orders and as otherwise necessary to comply with laws and regulations.
  • For our internal purposes such as accounting, auditing, data analysis, and research to improve and develop our products, services, content, advertising, and communications.
  • As described to you when collecting your Personal Information or subsequently agreed to by you.

 

Sharing of Personal Information

Sharing of Personal Information for a Business Purpose

Hibu may share your Personal Information with third parties for a business purpose, including in connection with the marketing or fulfillment of our products and services. When we disclose Personal Information for a business purpose, we require the recipient not to use such Personal Information other than for the stated business purpose. 

In the preceding twelve (12) months, we have shared the following categories of Personal Information with our service providers and third-party advertising partners for a business purpose:
Category A: Identifiers.
Category D: Commercial Information
Category F:  Internet or other similar network activity

Sale of Personal Information

Under the CCPA, 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.  In the preceding twelve (12) months, Hibu may be considered to have “sold” the following categories of Personal Information to certain social media services and search engines by using cookies and other tracking methods to collect information about a Consumer’s interaction with our websites, ads, videos or other media for purposes of retargeting advertising to such Consumers:
Category A: Identifiers
Category F: Internet or other similar network activity

 

Your CCPA Rights 

The CCPA provides Consumers with specific rights regarding their Personal Information.  This section describes your CCPA rights.

Information Access Rights

You have the right to request that Hibu disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and verify your request (see Exercising Your Information Access and Information Deletion Rights), 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:
    • for sales, the Personal Information categories that each category of recipient purchased; and
    • for disclosures for a business purpose, the Personal Information categories that each category of recipient obtained.

Information Deletion Rights

You have the right to request that Hibu delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and verify your request (see Exercising Your Information Access and Information 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 providers to:
1.    Complete the transaction for which we collected the Personal Information, provide goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2.    Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
3.    Debug products to identify and repair errors that impair existing intended functionality.
4.    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5.    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6.    Engage in 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.
7.    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8.    Comply with a legal obligation.
9.    Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt Out

The CCPA requires businesses that “sell” Personal Information to allow Consumers who are 16 years of age or older to direct us not to sell your Personal Information.  (See Exercising Your Right to Opt-Out from Sale of Personal Information.)  We do not sell the Personal Information of Consumer we actually know to be less than 16 years of age unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized such sale.

Non-Discrimination Rights

We will not discriminate against you for exercising any of your rights under the CCPA.  Unless permitted by the CCPA, we will not:

  • deny you products or services.
  • charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
  • provide you a different level or quality of products or services.
  • suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Information and will contain written terms that describe the incentive’s material aspects.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

Exercising Your Information Access and Information Deletion Rights

To exercise the Information Access and Information Deletion rights described above, please submit a verifiable request to us by either of the following methods:

Only you or a person registered with the California Secretary of State that you authorize 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.

You may make a verifiable request for information access not more than twice within any 12-month period.  The verifiable 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 of such person; and
  • include sufficient detail that allows us to properly understand, evaluate and respond to the request.

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.

 

Exercising Your Right to Opt-Out from Sale of Personal Information

If you would like to opt-out of the “sale” of your Personal Information, click Do Not Sell My Personal Information and fill out the form at the bottom of this page.

 

Exemptions 

The CCPA provides exemptions, through December 31, 2020, from certain of the requirements under the CCPA, including as to the following categories of Personal Information:

i)    The business-to-business exemption:

“personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency”

ii)    The employee / applicant / contractor exemption:

“(A)  Personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business.

(B)  Personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file.

(C)  Personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.”

 

Contact Us

For any questions or concerns about this Notice or about Hibu’s privacy practices, please contact us at Privacy.OfficerUS@hibu.com.

 

CCPA Online Request Form

The CCPA provides consumers (California residents) with specific rights regarding their personal information. You may use this webform to submit your requests as permitted by CCPA.
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