M.S. Project Zeus CY Limited dba ListBuilders Privacy Notice for California Residents
Effective Date: October 27, 2020
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of M.S. Project Zeus CY Limited dba ListBuilders and its affiliates (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. Other capitalized terms are defined in our Privacy Policy.
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 |
A. Identifiers. | 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. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
G. Geolocation data. | Physical location or movements. | NO |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
J. Non-public education information (per 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 educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
- Publicly available information from government records.
- De-identified 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
We collect information from you and other users of our Services as well as from third-party sources, such as trustworthy data providers, or from public sources and methods, such as information available on public APIs and the internet.
Active Collection of your data. We collect information from you when you use the Services. For example, we may ask you to provide contact information such as your name, email address, postal address, phone number, and other personal master data, communication data, and data to render an account for the Services performed. You can choose not to provide certain personal information but, if you choose to do so, you might not be able to take advantage of the Service.
We collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information) and may do so through a third-party payment process provider (the “Payment Processor”) in which case the information is collected and stored by the Payment Processor, and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.
Passive Collection. When you use the Service, some information may also be automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring website, and your activity on the Service. We may also automatically collect certain logistical information in server logs, including information about how you use various features of the Service and information about the number, frequency and length of each session.
We may also automatically collect certain information through the use of “cookies.” Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve the Service and your experience. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features or services made available on the Website.
We may use Web beacons or similar technology on the Website. Web beacons are small, invisible graphic images that may be used on the Website to collect certain information and monitor user activity, such as to count visits and understand usage effectiveness.
We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your personal information we collected.
We currently do not employ technology that recognizes “do-not-track” signals. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We use personal information collected through our Website for the purposes described in this notice and our Privacy Policy or disclosed to you on our Website or otherwise in connection with our services.
For example, we may use your information to:
- process and complete transactions in connection with the Services (e.g. to enable you to purchase products we offer on our Website);
- to request feedback and to otherwise contact you about your use of the Service;
- to respond to your emails, questions, comments, requests and complaints, and to provide customer service;
- to monitor and analyze Website usage and trends;
- to personalize and improve the Website, and our users’ experiences with the Website (such as providing content or features that match interests), and to increase the Website’s functionality and user friendliness;
- to send you confirmations, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, the Services;
- to notify you about important changes to the Service;
- to provide, evaluate and improve the Service;
- to keep the Services safe and to investigate, prevent, or take action regarding unlawful or harmful activities, including potential violations of our Terms of Service; and
- for any other purpose for which the information was collected.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share personal information with affiliates, third-party vendors, consultants, contractors and other service providers who work for us. Such third-party vendors may include vendors who provide software development services or fraud detection services to us and other third parties.
We may share aggregate statistical data for the improvement of our Services.
We share personal information with third parties who provide services to us, such as data collection, reporting, ad response measurement, and site analytics, as well as assistance with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. We and our third-party service providers, advertisers, and/or partners may also place web beacons for these third parties. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Policy.
We may disclose your personal information (i) to comply with laws and to respond to lawful requests and legal process, (ii) to protect the rights and property of ListBuilders, our agents and customers, and others, including to enforce our agreements, policies, and terms of use, and (iii) in an emergency to protect the personal safety of you, ListBuilders customers, or any other person.
We may disclose or transfer your personal information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, or acquisition transaction, or any bankruptcy or dissolution proceeding.
We may also share with third parties aggregated or de-identified information that does not identify you.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial Information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
In the preceding twelve (12) months, we have sold the following categories of personal information:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial Information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- 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 you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers 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 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.
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 email to: [email protected].
Only you or a person registered with the California Secretary of State that you authorize 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.
You 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 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.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you 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 you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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 your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. 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.
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 notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us the following email address: [email protected]