California Consumer Privacy Act (CCPA)

CCPA ONLINE PRIVACY NOTICE

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the SMARTe Privacy Policy. SMARTe has adopted this statement to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this statement.

General

This CCPA Notice provides further detail regarding (a) how we have processed Consumers’ personal information within the past twelve (12) months and (b) your rights under the CCPA.

Information SMARTe Collects

SMARTe collects personal information. We have collected the categories of personal information indicated below within the last twelve (12) months:

1. Identifiers

-> Personal Information Collected

  • Name
  • Internet Protocol address
  • Business email address
  • Job title and department
  • Business phone numbers (general, direct and fax)
  • Business related postal address of consumer
  • Social Networking URLs

-> Categories of Sources from which this Personal Information was Collected

  • Publicly available information
  • First-hand research
  • Submissions from SMARTe’s customers or freemium product users
  • Third-party data vendors
  • Directly and indirectly from activity on SMARTe’s website
  • Directly and indirectly from our customers or their representatives
  • Directly from vendors and other contractual counterparties
  • Through communications with prospective customers and other businesses and their representatives

-> Purpose for Collection of this Personal Information:

  • To fulfill or meet the purpose for which the information is provided.
  • To provide the consumer with information, products or services that the consumer requests from SMARTe.
  • To provide the consumer with email alerts, event registrations and other notices concerning SMARTe products or services, or events or news, that may be of interest to the consumer.
  • To carry out SMARTe’s obligations and enforce SMARTe’s rights arising from any contracts entered into between SMARTe and a SMARTe customer or other contractual counterparty, including for billing and collections.
  • To improve SMARTe’s website and present its contents to the consumer.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of SMARTe, our customers or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SMARTe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SMARTe is among the assets transferred.
  • To modify, enhance, or improve SMARTe’s services and/or provision such services to SMARTe customers.
  • To include in SMARTe’s database of business contacts, which SMARTe licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.

-> Categories of Third Parties with whom this Personal Information is Shared

  • SMARTe affiliates
  • Service Providers
  • SMARTe customers

Personal Information Categories Listed in the California Customer Records Statute

-> Personal Information Collected

  • Name
  • Business address
  • Business telephone number
  • Employment
  • Employment status

-> Purpose for Collection of this Personal Information

  • To fulfill or meet the purpose for which the information is provided.
  • To provide the consumer with information, products or services that the consumer requests from SMARTe.
  • To provide the consumer with email alerts, event registrations and other notices concerning SMARTe products or services, or events or news, that may be of interest to the consumer.
  • To carry out SMARTe’s obligations and enforce SMARTe’s rights arising from any contracts entered into between SMARTe and a SMARTe customer or other contractual counterparty, including for billing and collections.
  • To improve SMARTe’s website and present its contents to the consumer.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of SMARTe, our customers or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SMARTe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SMARTe is among the assets transferred.
  • To modify, enhance, or improve SMARTe’s services and/or provision such services to SMARTe customers.
  • To include in SMARTe’s database of business contacts, which SMARTe licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.

Categories of Third Parties with whom this Personal Information is Shared:

  • SMARTe affiliates
  • Service Providers
  • SMARTe customers

Internet or Other Similar Network Activity

-> Personal Information Collected

  • Information on a consumer’s interaction with a website, application, or advertisement
  • Internet Protocol address

-> Categories of Sources from which this Personal Information was Collected

  • Directly and indirectly from activity on SMARTe’s website.
  • Directly and indirectly from our customers or their representatives.
  • Through communications with prospective customers and other businesses and their representatives.

-> Purpose for Collection of this Personal Information

  • To carry out SMARTe’s obligations and enforce SMARTe’s rights arising from any contracts entered into between SMARTe and a SMARTe customer or other contractual counterparty, including for billing and collections.
  • To improve SMARTe’s website and present its contents to the consumer.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of SMARTe, our customers or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
  • To modify, enhance, or improve SMARTe’s services and/or provision such services to SMARTe customers.

Categories of Third Parties with whom this Personal Information is Shared:

  • SMARTe affiliates
  • Service Providers

Professional or Employment-Related Information

-> Personal Information Collected

  • Business email
  • Business telephone number
  • Business physical address
  • Current or past job history
  • Title

-> Categories of Sources from which this Personal Information was Collected

  • Publicly available information.
  • First-hand research.
  • Submissions from SMARTe’s customers or freemium product users.
  • Third-party data vendors.
  • Directly and indirectly from activity on SMARTe’s website.
  • Directly and indirectly from our customers or their representatives.
  • Directly from vendors and other contractual counterparties.
  • Through communications with prospective customers and other businesses and their representatives.

-> Purpose for Collection of this Personal Information

  • To fulfill or meet the purpose for which the information is provided.
  • To provide the consumer with information, products or services that the consumer requests from SMARTe.
  • To provide the consumer with email alerts, event registrations and other notices concerning SMARTe products or services, or events or news, that may be of interest to the consumer.
  • To carry out SMARTe’s obligations and enforce SMARTe’s rights arising from any contracts entered into between SMARTe and a SMARTe customer or other contractual counterparty, including for billing and collections.
  • To improve SMARTe’s website and present its contents to the consumer.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of SMARTe, our customers or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SMARTe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SMARTe is among the assets transferred.
  • To modify, enhance, or improve SMARTe’s services and/or provision such services to SMARTe customers.
  • To include in SMARTe’s database of business contacts, which SMARTe licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.

Categories of Third Parties with whom this Personal Information is Shared:

  • SMARTe affiliates
  • Service Providers
  • SMARTe customers

Disclosure or Sale of Personal Information and the Right to Opt-Out

We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to SMARTe’s customers for the purpose of business-to-business sales and marketing and recruiting and is provided subject to license agreements that limit its use to those purposes.

A consumer has the right to opt out of the sale of that consumer’s personal information by SMARTe by visiting our Privacy Center and submitting a request to remove the consumer’s profile or delete the consumer’s data. A consumer may also contact us by calling +1 (408) 834 8842 or by email to privacy@smarteinc.com. In order to submit a request, a consumer or an authorized agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.

In the preceding twelve (12) months, we have sold or disclosed the following categories of personal information for a business purpose

Category A:Identifiers
Category A:California Customer Records personal information categories.
Category I:Professional or employment-related information.

For avoidance of doubt, the personal information disclosed and/or sold by SMARTe within the identified categories is limited to business contact information related to a consumer’s profile as an employee of its employer. No sensitive personal information (i.e. Social Security number, passport number, medical or financial information) is collected, shared, disclosed, or sold by SMARTe.

We do not sell the personal information of minors under 16 years of age.

A Consumer’s Other CCPA Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

A consumer has the right to request that we disclose certain information to that consumer about SMARTe’s collection and use of that consumer’s personal information over the past 12 months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:

  • The categories of personal information we collected about that consumer.
  • The categories of sources for the personal information we collected about that consumer.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about that consumer (also called a data portability request).

Deletion Request Rights

A consumer has the right to request that SMARTe delete any of its personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.

We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer
  • 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 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 a consumer previously provided informed consent
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s 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 a consumer 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 by either:

Only a consumer or a person registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.

A consumer 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 SMARTe to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
  • Describe a consumer’s request with sufficient detail that allows SMARTe to properly understand, evaluate, and respond to it.

We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. 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 45 days of its receipt. If we require more time (up to 90 days), we will inform the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. 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 a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.

Non-Discrimination

We will not discriminate against a consumer for exercising any CCPA rights.

Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will provide notification by email or through a notice on our website homepage.

999.317(g)(1) Metrics

During the previous calendar year, SMARTe received the following number of requests from residents of California:

Received Complied Denied
The number of requests to know that the business received, complied with in whole or in part, and denied;
N/A*
N/A*
The number of requests to delete that the business received, complied with in whole or in part, and denied;
N/A*
N/A*
The number of requests to opt-out that the business received, complied with in whole or in part, and denied;
N/A*
N/A*

We anticipate our median number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out will be three (3) business days based on similar operations, however, given the effective date of the CCPA, we do not have these metrics at this time.

Contact Information

If there are any questions or comments about this statement, our Privacy Policy, the ways in which we collect and use a consumer’s personal information, how to receive a copy of the Privacy Policy and/or this statement in an alternative format (for consumers with a disability), a consumer’s choices and rights regarding such use, or wish to exercise consumer rights under California law, please do not hesitate to contact us at:

SMARTe Inc
1209 Lynbrook Way,
San Jose, CA 95129 USA
+1 (408) 834 8842
Email: privacy@smarteinc.com

Locations

1209 Lynbrook Way,
San Jose, CA 95129
+1 (408) 834 8842

27 Old Gloucester Street, London, WC1N 3AX
+44 (20) 3002 3649

1101 A, Vishwaroop IT Park, Sector 30-A, Vashi, Navi Mumbai 400703
+91 (22) 68384000

Locations

1209 Lynbrook Way,
San Jose, CA 95129
+1 (408) 834 8842

27 Old Gloucester Street, London, WC1N 3AX
+44 (20) 3002 3649

1101 A, Vishwaroop IT Park, Sector 30-A, Vashi, Navi Mumbai 400703
+91 (22) 68384000