Charlie Finance Co. Privacy Policy

Last Updated: June 22, 2020

This “Privacy Policy” describes the privacy practices of Charlie Finance Co. and our subsidiaries and affiliates (collectively, “Charlie, “we”, “ us”, or “our ”) in connection with our website located at www.hicharlie.com  and  proprietary, conversational, artificial intelligence-powered  Charlie Messaging application (“Bot”) which is made available to you via Facebook Messenger, SMS, or our mobile application (“Application”) (collectively, the “Services”), and the rights and choices available to individuals with respect to their information.  The Website, Bot  and the Application are collectively referred to herein as the “Company Properties.” Charlie may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

Table of Contents

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or otherwise includes:

  • Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
  • Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload and including the Account Credentials and other financial information you provide to us.
  • Profile information, such as your email address and/or Facebook messenger ID when you sign up with us.
  • Financial information, such as your financial institution’s name, names of  the financial account, the last four digits of the account, account balance, and certain transaction information (date, merchant, and amount of the transaction)  for accounts that you elect to connect to the platform. For more details on how we collect this type of information, please review the information about Plaid in the Third Party Vendors section, below.
  • Registration information that you provide to us when you establish an online account with us.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic information, such as your zip code if provided.
  • Technical information, such as your operating system type, browser type, browser language, and the geographic location of the computer system or mobile device that you are using to access the Service.
  • Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us.
  • Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service, as well as the frequency of your use of the Service.
  • Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
  • Website information, such as the website you viewed before browsing to our website, as well as pages you viewed, how long you spent on a page, access times, and information about your use of and actions on our website.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

See our Cookie Policy for more information.

Cookie Policy

In addition, we may make use of web beacons on the Services for user security purposes and in order to improve product service and evaluation. A web beacon is an object that is inserted in an e-mail or web page and is usually invisible to the user. The beacon allows checking that a user has viewed the page or e-mail, allowing us to track user services and website traffic more effectively.

We do not collect Personal Information via cookies or web beacons. If you have provided us with Personal Information separately, however, we may associate that information with the information that is collected automatically via cookies and web beacons and use such information to improve the Services. Automatic data collection may be performed on our behalf by our services providers who may provide us with reports about the data collected by such service providers.

Referrals

Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service.  We use your personal information to:

  • provide, operate and improve the Service
  • provide information about our products and services
  • establish and maintain your user profile on the Service
  • to retrieve your User Accounts statements and information regarding your transactions in order to provide you with the Services
  • facilitate your login to the Service via third-party identity and access management providers, such as Facebook
  • to provide you with support, handle complaints and collect fees and to conduct administrative activities necessary to maintain and provide our Services
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
  • communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about events or contests in which you participate
  • understand your needs and interests, and personalize your experience with the Service and our communications
  • provide support and maintenance for the Services
  • to conduct surveys and questionnaires
  • to enforce our Terms of Use
  • to comply with any applicable law and assist law enforcement agencies under any applicable law, when we have good faith to believe that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards
  • to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services
  • to take any action in any case of dispute, or legal proceeding of any kind between you and Charlie Finance, or between you and any other third parties or users with respect to, or in relation with the Services
  • respond to your requests, questions and feedback
  • for any other purposes disclosed at the time the Information is collected or to which you consent
  • and as otherwise specifically described in this Policy

For research and development.  We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications.  We may send you Charlie-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications  as described in the Opt out of marketing section below.

To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.   We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Affiliates.  We may share your personal information with our affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Third Party Vendors. We may sometimes share your personal information with Third Party Vendors or enable Third Party Vendors to collect information directly via our Services. Specifically, we work with a company called Plaid (www.plaid.com) to gather data for you about your accounts at other financial institutions from those financial institutions and from Plaid. By connecting your bank account through Plaid, you authorize us to share information with Plaid to authenticate you as an authorized user and  grant Plaid and any other Third Party Provider the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to the terms of Plaid’s privacy policy, available at https://plaid.com/legal/#end-user-privacy-policy, or that of any other Third Party Provider.

Additionally, we work with a company called AppsFlyer (www.appsflyer.com) to measure application installs and bank account connections. By using the Services, you grant AppsFlyer and any other Third Party Provider the right, power, and authority to collect information about your usage of the platform according to the terms of AppsFlyer’s privacy policy, available at https://www.appsflyer.com/product/security-and-privacy/, or that of any other Third Party Provider.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Government Authorities. We may disclose your Information to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas, or in connection with an audit of Charlie Finance or its affiliates. We also may disclose your Information to government authorities, and to other third parties when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of the Platform, or anyone else that could be harmed by such activities.

Additional service providers. We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. Such companies are authorized to use your information only for the purpose of performing their specific function on behalf of Charlie and under obligations similar to those in this Policy.

Change of Control. If we transfer our business relating to the Services, or any part thereof, to an affiliated company or a third party, including, but not limited to, by merger, sale of equity interests, sale of all or substantially all assets or other change of control transaction involving such business, then we will transfer your Information as part of the transferred assets to the acquirer of such business and you hereby give your prior consent thereto.

Third Party Payment Processor. If you are a Premium User, or if you are paying for a good or service through Charlie, we will share your credit card and other payment related information with a Third Party Payment Processor as necessary to process your payment. Storage by the Third Party Payment Processor of your credit card and other payment relating information is subject to the privacy policies and practices of the Third Party Payment Processor and is not subject to the terms of this Policy. By providing your credit card and other payment related information, you acknowledge and agree to use of such information by the Third Party Payment Processor for purposes of processing your payment to us.

Sharing of Aggregated Non-Personal Information. To the extent permitted by law, we may sell, license, distribute and disclose Aggregated Non-Personal Information to third parties.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Your Choices 

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@hicharlie.co.  You may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our Application may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Connecting via Facebook. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

Social Media Features and Widgets. Our Website may include social media features and widgets, including but not limited to the Facebook Like button. These features may collect information, including but not limited to, your IP address, the page you are visiting on our Website, and may set a cookie to enable the feature to function properly. All such social media features and widgets are either hosted by a third party or hosted directly on our Platform. Your interactions with these social media features and widgets are governed by the privacy policy of the company providing it.

Testimonials. We may display personal testimonials of satisfied customers on our Website in addition to other endorsements. With your consent, we may post your testimonial along with your full or partial name. If you wish to update or delete your testimonial, you can contact us at support@hicharlie.co.

Links to Other Sites. The Platform and the Services may contain links to Third Party Sites. We do not endorse such Third Party Sites and we are not responsible for the privacy practices of such Third Party Sites. Please refer to the privacy policies of such Third Party Sites for more information on how the operators of those sites collect and use your Personal Information.

Other sites, mobile applications and services

The Services may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security practices

We use commercially reasonable efforts to safeguard your Information from any unlawful interceptions or access, or other kinds of abuse and misuse. We implement a variety of systems, applications and procedures to do this. Among such security methods is the storing of your Information on ISO27001 certified cloud services, firewalls, encryption codes, authentication procedures and multi layer passwords. Furthermore, we implement employee supervision and prevent unnecessary access to data.

Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail, SMS, or MMS sent to or from the Platform may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail, SMS, or MMS.

The security of your information may be compromised if you lose possession or control of your mobile device or mobile phone number. You are solely responsible for maintaining the security of your mobile device from unauthorized access.

International data transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

Children are not allowed to use the Service, and we do not collect personal information from them. We define "children" as anyone under 18 years old.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to support@hicharlie.co. You may also write to us via postal mail at:

        Charlie Finance Co.

        Attn: Legal – Privacy

        360 Ritch St, Ste 205, San Francisco, CA, 94107

Your California Privacy Rights

Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at 360 Ritch St, Ste 205, San Francisco, CA, 94107 and support@hicharlie.co. You must put the statement "Your California Privacy Rights" in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Important information for California residents

This section applies only to California residents.  It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
  • Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales.  If we sell your Personal Information, you can opt-out.]  [In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
  • Opt-in.  If we are made aware that you are younger than 18 years old, we will delete your information.
  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How to exercise your rights

You may exercise your California privacy rights described above as follows:

  • Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:

  • Right to opt-out of the “sale” of your Personal Information.   Like many companies, we use services that help deliver interest-based ads to you.  Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you.  You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.  Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.

Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

Category of personal information (PI)
(click for details)

PI we collect

Source of PI

Business/commercial purpose for collection

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell” PI

Identifiers

  • Contact data
  • Identity data
  • Data about others
  • You
  • Public sources
  • Business partners

  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Affiliates
  • Advertising partners
  • Professional advisors
  • Authorities and others
  • Business transferees
  • Advertising partners

Commercial Information

  • Contact data
  • Identity data
  • Transaction data
  • Communications
  • Marketing data
  • You

  • Service delivery
  • Research & development
  • Marketing
  • Compliance & Operations
  • Advertising partners
  • Business transferees
  • Advertising partners

Financial Information

  • Financial data

  • You
  • Public sources
  • Business partners
  • Service delivery
  • Research & development

  • Business transferees

Online Identifiers

  • Device data
  • Identity data
  • Automatic collection

  • Service delivery
  • Marketing
  • Advertising partners
  • Advertising partners

Internet or Network Information

  • Device data
  • Online activity data
  • Automatic collection
  • Service delivery
  • Marketing
  • Advertising partners
  • Advertising partners

Geolocation Data

  • Device data

  • Automatic collection
  • Service delivery
  • Advertising partners
  • Advertising partners

Inferences

May be derived from your:

  • Device data
  • Online activity data

Professional or Employment Information

May be derived from your:

  • Financial data

  • Service delivery
  • Research & development
  • Marketing

Protected Classification Characteristics

We do not intentionally collect this information but it may be revealed in identity data or other information we collect




Glossary

Statutory category

Definition (categories may overlap)

Biometric Information

An individual’s physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Education Information

Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.

Financial Information

Bank account number, debit or credit card numbers, insurance policy number, and other financial information. [Does not include information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act.]

Geolocation Data

Precise location, e.g., derived from GPS coordinates or telemetry data

Identifiers

Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Inferences

The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Internet or Network Information

Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.

Medical Information

Personal information about an individual’s health or healthcare, including health insurance information.  [Does not include (a) medical information governed by California’s Confidentiality of Medical Information Act, (b) protected health information that is collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 or (c) information collected as part of certain clinical trials.]

Online Identifiers

An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.

Physical Description

An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).

Professional or Employment Information

This term is not defined in the CCPA, but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations).

Protected Classification Characteristics

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).

Sensory Information

Audio, electronic, visual, thermal, olfactory, or similar information.