Effective Date: Jan 2020
This Privacy Notice for California Residents supplements our Privacy Statement and applies solely to OutreachCircle customer and user, as defined below. In the event of any conflict between the terms of this notice and the Privacy Statement, the terms of this notice prevail
This notice details the rights of California residents under the California user Privacy Act of 2018 (CCPA).
1. Key definitions
1.1 Customer and User:
natural persons who reside in California, including (1) individuals who are in California for other than a temporary and transitory purpose; and (2) individuals who are domiciled in California, but are outside the state for a temporary or transitory purpose.
1.2. CCPA:
the California user Privacy Act of 2018, effective as of January 1, 2020, as amended or replaced from time to time, along with any implementing regulations.
1.3. Personal information:
as defined in the CCPA, and includes information that can be used to identify you, either alone or in combination with other information, and any other information that could reasonably be linked with a particular user or device.
2. Customer and user rights
As a customer and user, you have the right to know:
i. The categories of personal information we collect about you;
ii. The categories of sources from which the information was collected;
iii. The business or commercial purpose for collecting, disclosing, or selling personal information; and
iv. The categories of third parties we have disclosed personal information to for a business purpose and the categories of personal information disclosed.
Your access rights under the CCPA are not absolute. Specifically, the CCPA limits the information you can request to personal information collected in the 12-month period preceding our receipt of the request. Additionally, under the CCPA, OutreachCircle is not obligated to respond to requests for access to personal information more than twice in a twelve month period.
OutreachCircle may, in its sole discretion, choose to provide personal information in response to a user’s access request that relate to a time period greater than the preceding 12 months or respond to a user request more frequently than required by law; choosing to do so, however, does not constitute an obligation to do so.
You may request that OutreachCircle delete the personal information we process about you, subject to certain limitations. Your personal information may not be deleted if the information is necessary to:
i. Complete the transaction for which the personal information was collected, provide a good or service requested by the user, or reasonably anticipated within the context of a business’s ongoing business relationship with the user, or otherwise perform a contract between the business and the user.
ii. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
iii. Debug products to identify and repair errors that impair existing intended functionality.
iv. Ensure the right of another user to exercise his or her right of free speech, or exercise another right provided for by law.
v. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
vi. Engage in public or peer-reviewed, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the user has provided informed consent.
vii. To enable solely internal uses that are reasonably aligned with the expectations of the user based on the user’s relationship with the business.
viii.Comply with a legal obligation.
ix. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
c. Opt-out of sales
The CCPA provides you the right to opt-out of having your personal information sold by a business. OutreachCircle does not sell personal information to third parties.
d. Non-discrimination
The CCPA prohibits businesses from discriminating against a user for exercising their rights under the CCPA. OutreachCircle will not discriminate against you for exercising any of your CCPA rights.
e. Designated methods for submitting rights requests
Access and deletion rights may be exercised by contacting us directly to submit your request by clicking on ‘Contact Support/Contact Us/Help’ to send a request to update/remove their information. These requests are sent to outreachcircle@politicaldata.com with the subject line “CCPA Rights Request”.
Only you or someone legally authorized to act on your behalf may make a verifiable user request related to your personal information. Your request must:
i. Provide sufficient information that allows us to verify you are the person about whom we collected personal information or an authorized representative.
ii. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Generally, requests submitted through your OutreachCircle account will be considered sufficiently verified when the request relates to personal information associated with that specific account. However, if you have not created, or no longer have access to your OutreachCircle account, we may request additional materials or information for the purposes of validating the authenticity of your request.
OutreachCircle will use the information provided in connection with a verification request solely for the purposes of verification. We cannot effectuate your request if we are unable to verify your identity or authority to make the request and confirm that the personal information relates to you.
There may be other situations where OutreachCircle is unable or not required to effectuate your rights request. In such circumstances, OutreachCircle will respond to your request within the period required by the CCPA. The response will provide relevant details regarding OutreachCircle’s determination and any additional, pertinent information about your request.
3. Categories of personal information collected
When you choose to use our Services, including visiting our website, we may collect and process your personal information. OutreachCircle has collected the following categories of personal information from its users within the last twelve (12) months as necessary to provide our Services and/or as otherwise allowed under our Privacy Statement. The categories of personal information and other terms used below are defined in California Civil Code 1798.140, and may include reference to certain key definitions set forth in our Privacy Statement.
a. Information you provide directly to us
| Information | Description | Business or commercial purpose(s) of collection | Business purpose(s) for disclosure |
|---|---|---|---|
| Identifiers | Registration Information, such as your name zip code and email address. Web-Behavior Information, such as your device ID or IP address, automatically collected when you visit our website. Generally identifiers are provided directly to us, collected automatically when you visit our website, or created on your behalf when you sign up for our Services to allow OutreachCircle to provide our Services | Provide you with Services and analyze and improve our Services (Read more in our Privacy Statement) Allow you to share your information with others Share your information for research purposes For external research Provide customer support Conduct surveys or polls, and obtain testimonials Provide you with marketing communications | Identifiers are sometimes processed by our service providers for the following purposes: Audit Security Debugging Transient use OutreachCircle Research Quality assurance and product improvement |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) | Registration Information, such as your name and address. Self-Reported Information. Some personal information included in this category may overlap with other categories. | Provide you with Services and analyze and improve our Services Allow you to share your information with others Allow you to share your information for research purposes Provide customer support Provide you with marketing communications | California Customer Records information is sometimes processed by our service providers for the following purposes: Audit Security Transient use OutreachCircle Research Quality assurance and product improvement |
| Commercial information | Self-Reported Information, such as survey responses. User Content, such as information you share originating on OutreachCircle. Generally, this information is collected directly from you. | Provide you with Services and analyze and improve our Services Allow you to share your information with others Allow you to share your information for research purposes Provide customer support Conduct surveys or polls, and obtain testimonials Provide you with marketing communications | Commercial information is sometimes processed by our service providers for the following purposes: Audit Security Transient use OutreachCircle Research Quality assurance and product improvement |
b. Information collected through tracking technology (e.g. from cookies and similar technologies)
| Information | Description | Purpose of Collection | Business purpose(s) for disclosure |
|---|---|---|---|
| Internet or other electronic network activity information | Web-Behavior Information, including data generated from your use of our Services and collected through log files, cookies, web beacons, and similar technologies, (e.g., browser type, domains, page views). Our Cookie Policy contains more information about how OutreachCircle processes Web-Behavior Information. | Provide you with Services and analyze and improve our Services Allow you to share your information with others Allow you to share your information for research purposes Provide customer support Conduct surveys or polls, and obtain testimonials Provide you with marketing communications | Internet information is sometimes processed by our service providers for the following purposes: Audit Security Debugging Transient use OutreachCircle Research Quality assurance and product improvement |
| Geolocation data | Web-Behavior Information that includes the identification or estimation of physical location or movement. Our Cookie Policy contains more information about how OutreachCircle processes Web-Behavior Information. | Provide you with Services and analyze and improve our Services Allow you to share your information with others Allow you to share your information for research purposes Provide customer support Conduct surveys or polls, and obtain testimonials Provide you with marketing communications | Geolocation data is sometimes processed by our service providers for the following purposes: Audit Security Debugging Transient use OutreachCircle Research Quality assurance and product improvement |
OutreachCircle may share information listed with our service providers for operational business purposes including:
i. Audit: Auditing related to a current interaction and concurrent transactions.
ii. Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
iii. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
iv. Transient use: Short-term, transient use, where personal information is not disclosed to another third party and is not used to build a profile about a user or otherwise alter an individual user’s experience outside the current interaction.
v. OutreachCircle Research: Research that OutreachCircle performs with the intent to publish in a peer-reviewed journal.
vi. Quality assurance and product improvement: Activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by OutreachCircle, and otherwise to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by OutreachCircle.
d. Disclosures of personal information for a commercial purpose
If you have given your explicit consent, for example via a data transfer authorization or other consent document, we may disclose the categories of personal information detailed above for commercial purposes. The purpose, such as recruitment for external research, may vary and will be specified in the consent.
4. Changes to this notice
OutreachCircle will review and update this notice at least once every 12 months and more frequently as needed. We recommend visiting this page periodically to stay aware of any changes. If we modify this notice, we will make the revised notice available through our website.
5. Contact information
If you have questions about this notice, or wish to submit a complaint, request or inquiry, please email OutreachCircle's Privacy Administrator at privacy@politicaldata.com.