California Privacy Notice

Effective Date: June 14, 2021

CALIFORNIA RESIDENTS

This California Privacy Notice (this “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to California residents (“consumers” or “you”). This CA Notice describes how Edifecs, Inc. (“Edifecs”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (the “CCPA”). Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

PERSONAL INFORMATION

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This CA Notice does not apply to personal information we collect when we are acting as a “service provider” to process information pursuant to a contract with one of our business customers.

For the purposes of this CA Notice, personal information does not include:

  • Publicly available information from government records.
  • Deidentified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
  • Information excluded from the CCPA’s scope, such as:
    • 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;
    • 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 (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
  • Information relating to our job applicants, employees, contractors, and other Edifecs personnel.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for a variety of purposes. For example, we use personal information to provide you with information about our products and services, to provide our products and services to our customers, for the proper administration of our business, to improve our products and services for our customers, to protect the safety and integrity of our business, and to comply with legal obligations.

To learn more about the types of personal information we collect and the purposes for which we use this information, please refer to the “Our Collection of Personal Information” and the “Our Use of Personal Information” sections of our Privacy Notice.

In the last 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name and email address;
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your username and password and phone number;
  • Commercial Information, such as products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies;
  • Internet/Network Information, such as device information, logs and analytics data;
  • Geolocation Data, such as geolocation;
  • Sensory Information, such as voice recordings from customer service phone calls between you and Edifecs;
  • Other Personal Information, such as information you submit into the feedback form and any communications between you and Edifecs; and
  • Inferences, such as information generated from your use of the Services reflecting predictions about your interests and preferences.

We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit our Site or use our Services, and from third parties that you permit to share information with us.

DISCLOSURE OF PERSONAL INFORMATION

As described in the “Our Disclosure of Personal Information” section of our Privacy Notice, we share personal information with third parties for business purposes.

The categories of third parties to whom we disclose your personal information for a business purpose may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing and strategic partners; (iv) promotional partners; (v) ad networks and advertising partners; (vi) analytics providers; and (vii) social networks.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California Customer Records, Commercial Information, Internet/Network Information, Geolocation Data, Sensory Information, Other Personal Information and Inferences.

We do not sell personal information.

YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or, if applicable, selling the personal information.

The Right to Request DeletionYou have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information SalesYou have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To exercise your consumer rights, please submit a request by:

  • Filling out our California Consumer Rights Request Form;
  • Calling 1-855-333-4462; or
  • Emailing us at privacy@edifecs.com with the subject line, “California Consumer Rights Request”.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your name, email address, phone number, company name, and/or date of last interaction with Edifecs.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this California Privacy Disclosures where we can verify the authorized agent’s authority to act on your behalf. For consumer requests, we require the following for verification purposes: (a) receiving a power of attorney valid under the laws of California from you or your authorized agent; or (b) receiving sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf. We may also require you to verify your identity directly with us pursuant to the instructions set forth in these California Privacy Disclosures, and/or to confirm with us directly that you have provided the authorized agent permission to submit the request on your behalf.

Minors Under Age 16

Please contact us at privacy@edifecs.com to inform us if you are under the age of 16 and are interested in using our Services, or if you are the parent or guardian of someone under 16 who is interested in doing so. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

California’s “Shine the Light” Law

California's “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please contact us at privacy@edifecs.com and provide your contact information to be added to our suppression list.

ADDITIONAL INFORMATION

We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Effective Date” at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to privacy@edifecs.com.