Clientary CCPA Policy

This policy describes how Clientary uses and shares Personal Information of California residents in our capacity as a "business" under the California Consumer Privacy Act of 2018 ("CCPA"), and their rights under the CCPA.

This policy applies only if you are a California resident. For purposes of this policy, "Personal Information" has the meaning given in the California Consumer Privacy Act ("CCPA").

This policy does not apply to:

  • information exempted from the scope of the CCPA;
  • information collected in a business-to-business context, namely, where the information reflects our communications or transactions with you in the context of performing due diligence on, providing services to, or receiving services from, a company, partnership, sole proprietorship, non-profit or government agency where you are an employee, controlling owner, director, officer or contractor of that organization;
  • activities governed by a different privacy notice, such as notices we give to California personnel or job candidates; or
  • Personal Information we collect, use, and share on behalf of our customers as a "service provider" under the CCPA.

Your California Privacy Rights

You have the following rights:

  • Right to Know - Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information we have collected.
    • The categories of sources from which we collected the Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share the Personal Information.
    • The categories of Personal Information that we sold or disclosed for a business purpose.
    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
  • Right to Know - Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Right to Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Right to Opt-Out. You have the right to opt-out of any "sale" of your Personal Information as defined in the CCPA.
  • Right to Nondiscrimination. You are entitled to exercise the rights described above free from discrimination prohibited by the CCPA.

How to exercise your rights

We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to log into an online account (if applicable), provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information. These rights are not absolute, and in some instances, we may decline your request as permitted by law.

Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

Personal Information that we collect, use and disclose

The categories of Personal Information we collect are described below by reference to the statutory categories of Personal Information specified in the CCPA (California Civil Code section 1798.140):

  • Identifiers (excluding online identifiers), such as first and last names, email addresses, phone numbers, avatars, company name, your role in your company, social media profile information; photo ID that you provide if we ask you to verify your identity; and document signatures.
  • Commercial information, such as records of your transactions with us and services considered.
  • Financial information, such as your credit card information, billing and mailing address and other payment-related information.
  • Online identifiers, such as operating system type and version number, manufacturer and model; browser type; screen resolution; IP address; unique device identifiers; and Clientary internally assigned user identifiers.
  • Internet or network information, such as the website you visited before browsing to Clientary websites and services; how long you spent on a page or screen; navigation paths between pages or screens; session date and time; activity status (including first seen, last seen, last heard from and last contacted); pages viewed; links clicked; language preferences; tags applied within customer accounts; and other information about your interaction with our sites and services.
  • Geolocation data, the approximate location associated with your IP address.
  • Professional or employment information, such as your job title and organizational affiliation.
  • California Customer Records (listed in California Civil Code section 1798.80), such as the Professional or employment information, Financial information, Commercial information and Identifiers listed above.
  • Sensory information, such as photos you choose to submit in our services
  • Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and behavior.

Other potential data and sources of data are covered in our general Privacy Policy.

We do not sell your personal information in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your activity on ours and other online services. This is called interest-based advertising. The CCPA’s statutory definition of the term "sale" is broad and may include use of interest-based advertising services.