This Supplemental Privacy Notice supplements the information in our Privacy Policy, and except as provided herein, applies solely to California residents. It applies to the personal information we collect on or through Online Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to the personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to the personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Throughout our Privacy Policy, we describe the specific pieces of personal information we collect, the sources of that information, and how we share it. Under the CCPA, we also have to provide you with the "categories" of personal information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are identifiers (such as name, address, email address, phone number, other account information, and cookies); commercial information (such as transaction data); financial data (such as credit card and other financial account information); internet or other network or device activity (such as IP address or service usage); geolocation information (general location); inference data about you; sensory information (such as audio recordings if you call customer service); professional or employment-related data; education data; insurance (including health insurance) information; medical information; physical characteristics or description; legally protected classifications (such as gender); other information that identifies or can be reasonably associated with you.
We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Online Services; (3) affiliates; and (4) third parties such as social networks and other Provakil users.
We or our service providers may collect the above categories of information for the following business or commercial purposes:
We may also use the above categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
We describe our information sharing practices in our Privacy Policy. We may share certain categories of personal information with third parties for business purposes. For example, we may share identifiers and other information that identifies or can reasonably be associated with you with counterparties to your agreements. We may share identifiers with our marketing partners, and we may also share any of the categories described above with our subsidiaries and affiliates. If you connect your account with social media services or interact with social media plugins or links on the Online Service, we may share identifiers, commercial information, internet or other network or device activity, or general location with those social media services.
If you are a California resident, you may have certain rights. California law may permit you to request that we:
You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Online Services to you. If you ask us to delete it, you may no longer be able to access or use the Online Services.
In instances where we process personal information on behalf of our customer, rights requests should be directed to the relevant customer. Any request sent directly to us that pertains to information collected on behalf of a customer will be forwarded on to that customer.
If you would like to exercise any of these rights, you can submit a request at legal@initiohq.com, or through the form here . You will be required to verify your identity before we fulfill your request. To do so, you will need to provide information to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
California residents may opt-out of the "sale" of their personal information. The CCPA broadly defines "sale" in a way that may include allowing third parties to receive certain information such as cookie identifiers, IP addresses, and/or browsing behavior to add to a profile about your device, browser, or you. Such profiles may enable the delivery of interest-based advertising by such third parties within their platform or on other sites.
Depending on how you use the Service, we may share the following categories of information for such interest-based advertising, which may be considered a “sale” as defined by the CCPA: identifiers (such as IP address, device identifiers, and cookies) and internet and device activity. For information on how you can control or opt for such tracking technologies, see the “Analytics & Advertising” section above.
We do not share personal information with third parties for their direct marketing purposes.
The Online Services are not directed to children under the age of 13. We do not knowingly collect personal information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from children under 13. If we discover that an individual under 13 has provided us with personal information, we will delete the personal information to the extent required by COPPA.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
We may update this privacy policy to reflect changes to our information practices. If we make any material changes a notice may be posted on this page along with the updated Privacy Policy prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
If you have any questions or concerns regarding our Privacy Policy, please contact us at support@initiohq.com.