Information for Californian Consumers

Information for Californian Consumers

Updated: July 21, 2021

This part of the document integrates with and supplements the information contained in the rest of TrueNorth’s Privacy Policy and the provisions contained in this section apply to all users who are consumers residing in the state of California, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”). These provisions supersede any other possibly divergent or conflicting provisions contained in the Privacy Policy and the term “personal information” as it is defined in “The California Consumer Privacy Act of 2018” (CCPA) has the same meaning when used in this document.

Categories of Personal Information Collected, Disclosed or Sold

In this section we summarize the categories of personal information that we have collected, disclosed, or sold and the purposes thereof. 

Information We Collect

• Identifiers 
• Internet information.

How We Collect Information

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.
For example: 

• You directly provide your personal information when you submit requests via any forms on this Application
• You provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected
• We may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof

Disclosure of Information to Third Parties

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement. We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, to provide you with our Service. 

Sale of Your Personal Information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

Your Right to Opt-Out of the Sale of Personal Information & How to Opt-Out

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request. If you’d like to know more or exercise your right to opt out in regard to all the sales carried out by this Application, both online and offline, you can contact us for further information using the contact details provided in this document.

Why do We use Your Personal Information? 

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). 

• In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes, as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened, or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California Privacy Rights and How to Exercise Them

Right to Know

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

Right to Delete

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to Exercise Your Rights

• 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.

Response and Timing

We will confirm receipt of your verifiable request within (10) days and provide information about how we will process your request. We will respond to your request within (45) days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. Please note, we may take up to (90) days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period.
Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Updates to this Section

We may update this section to reflect changes to our information practices or in the regulations.  When we make changes to this section, we will post all changes and update the effective date accordingly.

Contact Information