Effective April 30th, 2020
This Supplemental Privacy Notice for California Residents supplements the information contained in the
Aktis, Inc. (“we” or “us” or “our”) Privacy
Policy 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 Platform collects 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”). In particular, we have collected (or not collected, if indicated below) the following categories of personal information from its consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, 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, address, telephone number, education, employment, employment history, credit card
number, debit card number, or any other methods of payment for our products, or medical 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), medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. These categories are ONLY collected in very limited circumstances where directly provided by the consumer voluntarily and knowingly. | NO |
| D. Commercial information. | Records of products or services purchased, obtained, or considered. | 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:
Direct interactions. You may give us your information by filling in forms or by corresponding with us by email. This includes, but may not be limited to, personal data you provide when you:
Create an account on our Platform;
Interact with the Platform such as listening and accessing;
Log in using an authentication partner (i.e., Google);
Click on an advertisement; or
Provide information by email.
Automated technologies or interactions. As you interact with our Platform, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical data from the following parties:
Analytics providers;
Advertising networks.
Data from publicly available sources such as internet search engines based inside and outside the United States.
Use of Personal Information
We may use and/or disclose the personal information we collect for one or more of the following business purposes:
To register you as a new subscriber
To manage our relationship with you which may include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Sending you the newsletter to which you subscribed
To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
To use data analytics to improve our Platform, products/services, marketing, customer relationships, and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you
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. When we disclose personal information for a business purpose, we require that the recipient both keep that personal information confidential and not use it for any purpose except performing the contract.
We disclose your personal information for a business purpose with the following categories of third parties:
Entities owned in whole or in part by Aktis, Inc.
Professional advisers including lawyers, bankers, auditors, and insurers who provide professional services.
Regulators and other authorities who require reporting of processing activities in certain circumstance.
Service providers
Other individuals, services, and partners at your request
Contests and promotions partners
Advertisers, ad networks and advertising partners
Social media networks
Entities for legal purposes
Sales of Personal Information
In the preceding twelve (12) months, we have not sold any categories of personal information (for both minors and non-minors). We do not sell personal information to third parties. While we do not sell your information to any third party in the traditional sense of the word ‘sell’, the definition of ‘sell’ provided in the CCPA is much more broad so we are providing notice that we may partner with third-party service providers and affiliate partners who may gain access to your personal information through the use of beacons, tracking pixels, or cookies.
California Information & Deletion Rights
If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share/disclose personal information;
Provide access to and/or a copy of certain personal information we hold about you;
Delete certain personal information we have about you; and
Provide you with information about the financial incentives that we offer to you, if any.
Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Platform to you.
Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, e-mail address, and physical address.
You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request.
Deletion Request Right
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, 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:
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, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
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
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at [email protected].
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.
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.
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 electronically using the email address you provide in your request.
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. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Provide you a different level or quality of goods or services.
Suggest that you may receive different goods or services or a different level or quality of goods or services.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described in this privacy policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at [email protected].