Effective Date: 01/01/2021
Last Revised on: 03/08/2023
Last Reviewed on: 03/08/2023
Notice at Collection:
Notice at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used.
A comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of your rights regarding your personal information, including:
Your right to know about personal information collected, used, disclosed or sold:
- Categories of personal information we collected in the preceding 12 months
- Categories of sources from which personal information is collected
- Categories of personal information, if any, we disclosed or sold in the preceding 12 months
- For each category identified as disclosed or sold, categories of third parties to whom the information was disclosed or sold
- For each category, how long we retain the personal information
- Notice that we do not sell or share your personal information, if applicable
- Your right to access your personal information
- Your right to request correction of your personal information
- Your right to request deletion of your personal information
- Your right to opt out of the sale or sharing of your personal information
- Your right to limit the sale or sharing of your sensitive personal information, if used for cross-contextual behavioral advertising, if applicable
- Your right to access information about automated decision making, if applicable, and your right to reject automated decision making and profiling
- How to submit a verified consumer request for your Rights to Know, Correct, or Delete, opt out, or limit the sharing of sensitive personal information
- How to use an authorized agent to submit a verified consumer request
- Your right to non-discrimination for the exercise of your privacy rights
- Other California privacy rights
- Changes to our privacy notice
- Our contact information
- Your right to know about personal information collected, used, disclosed or sold:
Notice at Collection
The purpose of this Notice at Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used.
|Do We collect?||Categories of Personal Information|
|[ x ]||A. Identifiers: For example, 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.|
|[ x ]||B. Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, 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.|
|[ x ]||C. Characteristics of CA or Federal Protected Classifications: For example, race, religion, national origin), age (40 and over), gender, sexual orientation, medical condition, ancestry, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), familial status, disability, veteran status, or genetic information.|
|[ x ]||D. Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|[ x ]||E. Biometric Information: For example, physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.|
|[ x ]||F. Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement|
|[ x ]||G. Geolocation Data: For example, information that can be used to determine a device’s physical location|
|[ x ]||H. Sensory or Surveillance Data: For example, audio, electronic, visual, thermal, olfactory, or similar information that can be linked or associated with a particular consumer or household|
|[ x ]||I. Professional or Employment-Related Information: For example, compensation, evaluations, performance reviews, personnel files and current and past job history.|
|[ x ]||J. Education Information (defined as information that is not publicly available personally identifiable information as defined in 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 education institution or party acting on its behalf, for example, non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information.|
|[ x ]||K. Profile Data: For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
|[ x ]||L. Sensitive Personal Information: For example, social security number, driver’s license number, account login, debit or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of emails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data.|
Please note that 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 (CalFIPA), and the Driver's Privacy Protection Act of 1994.
We use the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided
- With your consent or authorization
- For our internal operation purposes
- For auditing relating to consumer transactions including ad impressions and compliance with regulations
- Fraud and security detection
- Debugging to identify and repair errors
- Short-term data use for the current interaction that is not used to build a profile
- Servicing transactions and accounts (e.g., customer service, maintaining and servicing accounts, customer verification, payment processing) and providing services on behalf of business or service provider (e.g., financing, advertising or marketing, analytics)
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business
- To share the personal information with service providers to carry out other business purposes
We do not use any sensitive personal information you directly provide to us such as social security numbers or government identification for cross-context behavioral advertising, but if you have enabled location services, your geolocation information may be used for this purpose. You may limit the use of your geolocation information for this purpose by making a request as outlined below, or by turning off location services on your device. We never collect sensitive personal information for the purpose of inferring characteristics about you.
We will not collect additional categories of personal information without providing you a new Notice at Collection disclosing those categories.
Your Right to Know
You have the right to request that we disclose what personal information we collect, use, disclose, and sell. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
We collect personal information, which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.
|Category||In the preceding 12 months this category was:||Categories of third parties to whom the information was disclosed|
|A. Identifiers||[ x ]||[ x ]||
|B. Personal Information Categories from Cal. Civ. Code § 1798.80(e)||[ x ]||[ x ]||
|C. Characteristics of CA or Federal Protected Classifications||[ x ]||[ x ]||
|D. Commercial Information||[ x ]||[ x ]||
|E. Biometric Information||[ x ]||[ x ]||
In the context of customer care call recordings:
|F. Internet or Other Similar Network Activity||[ x ]||[ x ]||
|G. Geolocation Data||[ x ]||[ x ]||
|H. Sensory or Surveillance Data||[ x ]||[ x ]||
In the context of customer care call recordings:
|I. Professional or Employment-Related Information||[ x ]||[ x ]||
|J. Education Information||[ x ]||[ x ]||
|K. Profile Data||[ x ]||[ x ]||
The categories identified as collected in the table above were collected from the following categories of sources:
- You directly
- Your current or former spouse
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
Your Right to Correct Your Personal Information
You have the right to request that we correct any of your personal information collected by us that is inaccurate, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
We may decline to process your correction request if we are unable to verify your identity, if the request is manifestly unfounded or excessive, or if the information is publicly available information, certain medical information, consumer credit reporting information, or other types of information exempt from the CCPA.
Your Opt-Out Choices
While we do not sell or share your personal information for monetary purposes, the definition of “sale” in California includes the sharing of personal information for targeted advertising and analytics. Because we use companies like Google Analytics and Facebook ads, our non-monetary uses of your personal information may be considered a “sale” under the CCPA. You may contact us to opt out of the sharing of your information for this purpose. We do not knowingly sell the personal information of minors under 16 years of age. You also may contact us to limit the use of your sensitive personal information, specifically, your geolocation information, if you have enabled it. We never share your Social Security Number for any purpose other than the purpose for which you provided it to us.
Your Right to Request Deletion of Your Personal Information
You have the right to request that we delete any of your personal information collected by us, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
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.).
- 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Submitting a Verified Consumer Request
You have the right to submit verified consumer requests to know information, correct information, or for deletion. You may also request to opt out of the sale or sharing of your personal information, or to limit the use of your sensitive personal information.
The request to know can be for any or all of the following:
- Specific pieces of personal information that we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which the personal information was collected;
- Categories of personal information that we sold or disclosed for a business purpose about you;
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose;
- The business or commercial purpose for collecting or selling personal information;
- The length of time we intend to retain each category of personal information.
The response to a request for any of the categories above will cover the preceding 12 months. Please note that we are not required to provide personal information to you more than twice in a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will either treat it as if it had been submitted in accordance with our designated methods or provide you with information on how to submit the request or remedy any deficiencies.
Your request will be verified by matching the information you provide to information that we have collected. Categories may include, but are not limited to, name, address, telephone number, last 4 digits of your social security number, last 4 digits of the credit card you used to pay for your order, a prior order number, or similar types of data we hold.
Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
If requests from you are manifestly unfounded or excessive in particular because of their repetitive character, we may either charge a reasonable fee or refuse to act on the request, notifying you of our reason for refusing to act. If we determine that the request warrants a fee, we will notify you of the reason for that determination and provide you with a cost estimate before completing your request.
Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data.
Requests to Know or Delete for Child Under the Age of 16: We accept requests for minors under the age of 16 if we can determine that it was submitted by a parent or guardian. If submitting such a request, please provide sufficient documentation to demonstrate that relationship.
Using an Authorized Agent to Submit a Request
Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request.
If you’re an authorized agent making a request you need to do the following:
(a) provide a copy of a power of attorney provided to you by the consumer pursuant to Probate Code sections 4000 to 4465; or
(b) provide proof of signed permission along with a copy of your ID and have the consumer confirm with us that they provided you permission to submit the request by sending an e-mail.
Requests to Access, Correct, or Delete Household Information
We will not comply with a request to know specific pieces of information, correct personal information, or a request to delete household personal information unless (i) the request is made by the account holder or (ii) all consumers of the household jointly request access to specific pieces of information or deletion, we can individually verify all members of the household and we can verify each is currently a member of the household. If a member of a household is a minor under 16, we must obtain verifiable consent before complying with a request for specific pieces of information for the household or deletion of household personal information.
Your Right to Non-Discrimination for the Exercise of a Privacy Right
You have a right not to receive discriminatory treatment by the business for the exercise of the privacy rights conferred by the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. You can submit requests by calling 833-462-0664 or using our webform.
Company honors Web browser “do not track” signals.
Other parties may collect personally identifiable information about your activities over time and across different Web sites when a consumer uses our Site or service.
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Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact for More Information
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Attn: General Counsel
75 State Street, 1st Floor, Boston, MA 02109.