Privacy Notice for California Residents

Updated 01 January 2023

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Supermetrics Group (collectively, “we,” “us,” or “our”) and applies solely to consumers who reside in the State of California (“consumers” or “you”). We adopt this statement to comply with the California Consumer Privacy Act of 2018 incorporating any amendments thereto, including but not limited to the California Privacy Rights Act (together, “CCPA”) and other California privacy laws. Any terms defined under applicable privacy laws have the same meaning when used in this statement. For California residents, the provisions of this Privacy Notice for California Residents prevail over any conﬂicting provisions of the Privacy Policy of Supermetrics Group.

1. Information We Collect

We collect 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 the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
Identifiers.	Name, customer number, username and/or other identifier, preferred language, Internet Protocol address, email address or other similar identifiers.	YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Information related to the company’s contact persons such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, or medical information (special diets) if provided to us in connection with us organizing events. Some personal information included in this category may overlap with other categories.	YES
Commercial information.	Records of customer relationship and the contract such as past and current contracts and orders, correspondence with you and other communication, payment information, commercial and event invoices, other information which you have voluntarily provided to our systems, or other purchasing or consuming histories or tendencies.	YES
Internet or other similar network activity.	Data of the connection and terminal device you are using such as the IP address, device ID or other device identifier and cookies	YES
Sensory data.	Sales calls recordings.	YES

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope.

2. Collection, Disclosure, and Use of Personal Information

We obtain the categories of Personal Information listed above as described in the Supermetrics Group Privacy Policy Section 4 ‘From where do we receive data?’

We use the categories of Personal Information listed above as described in the Supermetrics Group Privacy Policy Section 3 ‘What data do we process and what is the purpose and the legal basis of processing the personal data?’

We disclose the categories of Personal Information listed above as described in the Supermetrics Group Privacy Policy Section 5 ‘To whom do we disclose data, and do we transfer data outside of EU or EEA?’

We retain the categories of Personal Information listed above as described in the Supermetrics Group Privacy Policy Section 6 ‘How do we protect the data and how long do we store them?’

For more information regarding our use of Cookies, please review our Cookie Policy.

3. Your Rights and Choices

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Us section below with a reference to California Disclosure Information.

Under CCPA, consumers have certain rights regarding their Personal Information, as described below.

Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
- The categories of Personal Information that we collected about you;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information;
- The categories of third parties with whom we share Personal Information;
- The specific pieces of Personal Information that we have collected about you;
- The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
- For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.

Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell any Personal Information.

Right to Opt-In: We do not have actual knowledge that we collect, share, or sell the Personal Information of minors under the age of 16.
Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for “the purpose of inferring characteristics about a consumer.” However, we do not collect or process Sensitive Data for this purpose.
Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.

If you would like to exercise your California rights, please refer to the Consumer Requests and Verification section below.

4. Consumer Requests and Verification

Right to Non-Discrimination

We may not discriminate against you because you exercise any of your rights under CCPA, including, but not limited to:

Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Verifying Requests

You may request to exercise your rights of access, deletion, or correction under CCPA by contacting us as described in the Contact Us section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:

As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
We will confirm that you want your information accessed, corrected, and/or deleted.
We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.

Authorized Agents

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Us section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:

The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
You to verify your identity directly with us; or
You to directly confirm with us that you provided the authorized agent permission to submit the request.

5. Changes to Our Privacy Notice

Should we make amendments to this Privacy Policy, we will place the amended notice on our website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you review this Privacy Policy from time to time to ensure you are aware of any amendments made.

6. Contact Us

If you have questions about this privacy policy, or the privacy practices of Supermetrics Group, or to exercise any of your privacy rights detailed above, please contact us at privacy@supermetrics.com or (888) 571-3960.