Last updated: June 8, 2023
Application of CCPA.
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents who are natural persons have the following rights:
1. The right to request that we identify the categories of the requesting consumer’s personal information we have collected, the source of that information, our use of that information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold;
2. The right to request a copy of the specific personal information collected about the requesting consumer during the 12 months before their request;
3. The right to request that such information be deleted (subject to certain exceptions);
4. The right to request that the requesting consumer’s personal information not be sold to third parties; and
5. The right of a requesting consumer not to be discriminated against for exercising any of the rights listed above.
This notice pertains to your personal information. Personal information is defined in the CCPA, and we use that definition within this notice. We will also reference some other terms from the same law, such as “consumer,” “business,” “business purpose,” or “commercial purpose,” and those also have the definitions set out in that law.
When we talk about a “sale,” or “selling,” personal information, we are using the definitions of “sale,” and “sell” as defined in the CCPA. This means that we don’t sell, rent, or otherwise disclose your personal information in exchange for money or something else of value.
Submitting requests for personal identification and/or production
The CCPA allows a California consumer to request the identity and/or production of their personal information collected by us. You may make such a request by emailing us at firstname.lastname@example.org. The CCPA limits a requesting consumer to two (2) personal information requests in a 12-month period. We will use commercially reasonable efforts to respond within 45 days of receiving a personal information request. In order to respond, we will need to collect information from the requesting consumer so that we can verify their identity in connection with such requests.
Information we collect
We collect 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”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A 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.||YES|
|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.||YES|
|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.||YES|
|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.||YES|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase or from communications with you such as when you contact ParkHub (whether in person, by mail, by phone, online, via electronic communication or by any other means).
- Indirectly from you. For example, from observing your actions in connection with your use of our products or services.
- From other third parties.
a. From our independent contractors and resellers. We may receive information about you from our independent contractors and resellers.
- Third party service providers. For example, when you choose to make an electronic payment through a merchant or reseller, we may receive personal information about you from third parties such as payment service providers, for the purposes of that payment.
- From other third parties. We may collect information from third parties such as consumer data resellers.
- From public sources. For example, we may collect information from public records.
Sharing of personal information.
We may disclose your personal information to a third party for a business purpose. We use third party service providers to fulfill our obligations under our agreement with you and for our own business purposes. We may also sell your personal information to third parties, subject to your right to opt-out of those sales (see “Personal Information Sales Opt-Out” below).
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Independent contractors.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your access and deletion rights.
You have the right to request that we delete any of your personal information which we have collected from you. Except as described below, upon our receipt of such a request, we will delete the personal information from our records and direct any of our service providers to whom we have disclosed that personal information to delete it from their records.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• complete the transaction for which we collected the personal information, provide the product or service that you requested, or otherwise take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform pursuant to a contract we have with you;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• debug our products or services to identify and repair errors that impair existing intended functionality;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• 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 businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have 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; or
• make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Opting out of the sale of personal information
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Our products and/or services are not intended for minors. 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 at least 13 but not yet 16 years of age, or the parent or 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.
The following are not considered sales of personal information under the CCPA:
• a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the CCPA. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions. Hovering over, muting, pausing, or closing a given piece of content does not constitute a consumer’s intent to interact with a third party.
• The business uses or shares an identifier for a consumer who has opted out of the sale of the consumer’s personal information for the purposes of alerting third parties that the consumer has opted out of the sale of the consumer’s personal information.
• The business uses or shares with a service provider personal information of a consumer that is necessary to perform a business purpose if both of the following conditions are met:
• The business has provided notice of that information being used or shared in its terms and conditions consistent with the CCPA.
• The service provider does not further collect, sell, or use the personal information of the consumer except as necessary to perform the business purpose.
We must disclose some personal information in order to provide the products and/or services for which we have been contacted by you, to comply with bank and card brand rules, and to comply with state and federal laws. From time to time, we also share personal information for commercial purposes.
To exercise the right to opt-out, you (or your authorized representative) may submit a verifiable consumer request to us by emailing email@example.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time.
No financial incentives.
The CCPA requires businesses to notify consumers of any financial incentives for allowing the sale of their personal information. We offer no such incentives. If we change our practice, though, we will amend this notice to ensure compliance with the CCPA.
Non-discrimination for exercising new rights.
Consumers have a right not to be subjected to discriminatory treatment for exercising the privacy rights conferred by the CCPA.
Material changes in our practices or in the law.
We may modify this notice where required, such as due to a material change in our business practices with respect to your personal information or due to a material change in the CCPA. If this happens, we will post the updated notice on our website at www.parkhub.com and update the notice’s effective date. Your continued use of our products and/or services following the posting of changes constitutes your acceptance of such changes.