Effective Date: [January 1, 2020]
Last Reviewed on: [January 1, 2020]
This California Privacy Addendum (this “Addendum”) of Frontsteps, Inc. (“us,” “we,” or the “Company”) is part of and supplements the information contained in the Company’s Privacy Policy https://www.frontsteps.com/privacy-policy. This Addendum applies solely to all visitors, users, and others who reside in the State of California (each, a ”consumer,” or “you”) who access our website, https://www.frontsteps.com/ (our “Website”), or otherwise interact with us as described in our Privacy Policy. We adopt this Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Addendum.
Information We Collect
Our Website collects 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, our Website has collected the following categories of personal information from our users within the last 12 months:
We obtain the categories of personal information listed above from the following categories of sources:
Personal information does not include:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
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 disclose your personal information to a third party for a business purpose. When we disclose personal information for a 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 contract. [We share your personal information with the following categories of third parties: service providers and data aggregators.]
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, the Company has not disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding 12 months, the Company has not sold personal 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 (see “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:
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 (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct any applicable 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 provider(s) to:
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:
Only you, or someone legally authorized 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:
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 45 more 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 the12-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:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
In addition to your rights under the CCPA, a business subject to California Civil Code § 1798.83 is required to disclose to its California customers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes. Please note that we are only required to respond to such a customer request once during any calendar year, and only if we are covered by such California Civil Code section. If you are a California resident and would like to make such a request, contact us via our online contact form at https://www.frontsteps.com/contact-us. Please be aware that not all information sharing is covered by this California law and only information sharing that is covered will be included in our response. We reserve the right not to respond to requests submitted via other means other than our online contact form.
Changes to Our Privacy Addendum
We reserve the right to amend this Addendum at our discretion and at any time. When we make changes to this Addendum, we will post the updated Addendum on the Website and update the effective date of the Addendum. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this Addendum, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1-888-315-6656
Website: https://www.frontsteps.com/contact-us
Email: CCPA@frontsteps.com
Postal Address:
Frontsteps, Inc.
Attn: CCPA Compliancy Team
1290 N Broadway Ste. #1400
Denver, CO 80203