ClickGUARD
GCPA Information
Effective Date: May 1st, 2022
Table of contents
CCPA Information
Overview
Information we collect and ways we may use it
Collection
Uses
Examples
Sharing personal information
Sale of personal information
Your rights and choices
Access to Specific Information and Data Portability Rights
Deletion Request Rights
Exercising Access, Data Portability, and Deletion Rights
Response Timing and Format
Contact us
Overview
This CCPA Information supplements the information containedin the ClickGUARD Privacy Policy as well as other agreements you have withClickGUARD, such as the ClickGUARD Terms of Service. It applies to visitors,participants, customers and users of ClickGUARD’s Platform and Services whoreside in the State of California. Any terms we use in this notice that aren’tdefined here will have the meanings we give them in those agreements.
The California Consumer Privacy Act (CCPA) is a privacy law that provides avariety of privacy rights to California consumers. The law includes a provisionthat gives California residents the right to opt out of the “sale” of their“personal information” through a prominent link that says “Do Not Sell MyPersonal Information” on the “selling” party’s homepage. The CCPA includescertain exceptions to the definition of “sale”, including transfers to “serviceproviders”.
This Notice provides California consumers with additional information about our collection and use of your Personal Information.
Information we collect and ways we may use it
Through our Site, Platform and Services, we collect information that can be used to identify or describe you or that could reasonably be linked, directly or indirectly, with a particular consumer or device as defined in the CCPA (“Personal Information”).
Collection
As explained in more detail in our Privacy Policy, ClickGUARD obtains Personal Information from the following categories of sources:
- Directly from you
- For example, when you sign up to receiveinformation from ClickGUARD, to register an account with ClickGUARD or to useour Platform or Services; and
- Indirectly through other sources
- For example, from observing your actions on ourSite, including by the use of cookies, or from third parties.
Uses
The purposes for which we use the Personal Data we collect are set out in our Privacy Policy. We refer to them as legitimate business purposes in our Privacy Policy and in this Information document.
Examples
For example, we collect the following categories of Personal Information from California consumers:
Information that can be used to identify you ("Identifiers")
Examples include: a real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name
Uses: We use Identifiers for all of our legitimate business purposes.
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples include: a name, signature, address, telephone number, employment
Uses: To provide access to the Platform and Services, improve your experience, and analyze usage for functionality and product development.
Protected classification characteristics under California or federal law
Examples include: birth year, gender
Uses: To improve your experience with the Platform and Services, and to analyze usage for functionality and development.
Commercial information
Examples include: records of products purchased or considered, purchasing or consuming histories or tendencies
Uses: To process payments, enhance your experience, and analyze usage for technical functionality and product development.
Internet or other similar network activity
Examples include: browsing history, interactions with a website or application
Uses: To improve your experience, and to analyze how you interact with the Platform and Services for technical functionality.
Geolocation data
Examples include: physical location or movements
Uses: To protect against fraud and provide technical functionality.
Sensory data
Examples include: video and audio recordings, visual information
Uses: To provide access to the Platform and Services, enhance your experience, and analyze interactions for technical functionality.
ClickGUARD will not collect additional categories of Personal Information or use the collected information for unrelated or incompatible purposes without providing notice.
Sharing personal information
ClickGUARD may share your Personal Information with a third party for a legitimate business purpose. When we disclose Personal Information for a legitimate business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the services for us.
We disclose your Personal Information for a legitimate business purpose to the following categories of third parties:
- Companies that perform tasks to help us provide the following Services: hosting service providers, user engagement and customer support providers, job application service providers, payment service providers, communication tools, and analytics tools; and
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.
ClickGUARD may share your Personal Information with a third party for a legitimatebusiness purpose. When we disclose Personal Information for a legitimatebusiness purpose, we enter a contract that describes the purpose and requiresthe recipient to both keep that Personal Information confidential and not useit for any purpose except performing the services for us.
Sale of personal information
In the preceding twelve (12) months, ClickGUARD has not sold any Personal Information as contemplated under the CCPA.
Your rights and choices
The CCPA provides California Consumers 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 ClickGUARD disclosecertain information to you about our collection and use of your PersonalInformation over the past 12 months. Once we receive and confirm yourverifiable consumer request (see Exercising Access, Data Portability, andDeletion Rights), 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 legitimate business purpose for collecting or selling that PersonalInformation.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also calleda data portability request).
- If we sold or disclosed your Personal Information for a legitimate businesspurpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category ofrecipient purchased; and
- disclosures for a legitimate business purpose, identifying the PersonalInformation categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that ClickGUARD delete any ofyour Personal Information that we collected from you and retained, subject tocertain exceptions. Once we receive and confirm your verifiable consumerrequest, we will delete (and direct our service providers to delete) yourPersonal 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 provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that our customers purchase or request, 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. PenalCode § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statisticalresearch in the public interest that adheres to all other applicable ethics andprivacy laws, when the information’s deletion may likely render impossible orseriously impair the research’s achievement, if you previously providedinformed 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 either:
- Calling us at: (888) 877‒1882
- Emailing us at privacy@ClickGUARD.com
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 authorizedre presentative.
- Describe your request with sufficient detail that allows us to properlyunderstand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information ifwe cannot verify your identity or authority to make the request and confirm thePersonal Information relates to you.
Making a verifiable consumer request does not require you to create an accountwith us. We will only use Personal Information provided in a verifiableconsumer request to verify the requestor’s identity or authority to make therequest.
Response Timing and Format
We endeavor to respond to a verifiable consumer requestwithin forty-five (45) days of its receipt. If we require more time (up to 90days), we will inform you 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 theverifiable consumer request’s receipt. The response we provide will alsoexplain the reasons we cannot comply with a request, if applicable. For dataportability requests, we will select a format to provide your PersonalInformation that is readily useable and should allow you to transmit theinformation from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumerrequest unless it is excessive, repetitive, or manifestly unfounded. If wedetermine that the request warrants a fee, we will tell you why we made thatdecision and provide you with a cost estimate before completing your request.
Contact us
If you have any questions or comments about this notice, the ways in which ClickGUARD collects and uses your information described below and in this CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at privacy@ClickGUARD.com or by mail:
ClickGUARD INC
1931 CORDOVA RD #3114
Fort Lauderdale, FL 33316
Attn: Operations MGR