Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
Use of Personal Information
We may use, or disclose the personal information we collect and, over the prior twelve (12) months, have used, or disclosed the personal information we have collected, for one or more of the business and commercial purposes described in our Privacy Notice. Sharethrough 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.
Sources of Personal Information
Sharethrough obtains the categories of personal information listed above from the categories of sources described in our Website Privacy Notice:
Sharing Personal Information
Sharethrough may disclose your personal information to a third party for the business purposes described in the Website Privacy Notice. 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.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Sharethrough has disclosed the following categories of personal information for a business purpose to the listed categories of third parties:
A. Identifiers:
Categories of Third Parties: Service Providers; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
B. California Customer Records personal information categories:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
D. Commercial information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
F. Internet or other similar network activity:
Categories of Third Parties: Service Providers; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
G. Geolocation data:
Categories of Third Parties: Service Providers; Advertisers and advertising networks; Affiliates, parents, and subsidiary organizations of Sharethrough; Internet cookie information recipients, such as analytics and behavioral advertising services;
I. Professional or employment-related information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
K. Inferences drawn from other personal information:
Categories of Third Parties: Service Providers; Affiliates, parents, and subsidiary organizations of Sharethrough;
Sales of Personal Information
As noted in our general Privacy Policy, we do not sell your personal information as the term “sell” is commonly understood to require an exchange for money. However, the California State Attorney General may issue guidance on whether the use of advertising and analytics cookies on our Website may be considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA to include both monetary and other valuable consideration. Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our Website and will comply with the restrictions of the “sale” of this information to the extent technologically feasible. This “sale” would be limited to our use of third-party advertising and analytics cookies and their use in providing you behavioral advertising and their use in understanding how people use and interact with our Website(s).
In the preceding twelve (12) months, Sharethrough has not “sold” your Personal Information for either monetary or other valuable consideration.
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. You may exercise these rights yourself or through your authorized agent.
Access to Specific Information and Data Portability Rights
This information supplements the information described in the Website Privacy Notice with respect to your rights regarding your personal information. If this section conflicts with the Website Privacy Notice, the sections that provide you with the broadest rights will control.
You have the right to request that Sharethrough disclose certain information to you about our collection and use of your personal information over the past 12 months (a “Right to Know” request). You also have the right to request that we provide you with a copy of the specific pieces of personal information that we have collected or created about you. If you make a request for the specific pieces of personal information electronically, we will provide you with a copy of your personal information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the personal information to another third-party. You must specifically describe if you are making a Right to Know request or a request for the specific pieces of personal information. If you would like both the information about our collection and use over the past twelve (12) months and a copy of the specific pieces of Personal Data, you must make both requests clear in your email. If it is not reasonably clear from your request, we will only process your request as a Right to Know request.
Once we receive your request and verify your identity (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
For Right to Know requests:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
For requests for specific pieces of personal information:
- The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights
You have the right to request that Sharethrough 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 our 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:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, 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. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed 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
In addition to the methods to exercise your rights described in the Website Privacy Notice, to exercise the right to know, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
If you (or your authorized agent) submit a request to delete your information online, we will use a two-step process in order to confirm that you want your personal information deleted. This process may include verifying your request through your email address on record, calling you on your phone number on record (which may include an automated dialer), sending you a text message and requesting that you text us a confirmation, or sending you a confirmation through US mail.
If you fail to make your submission in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above, or provide you with information on how to submit the request or remedy any deficiencies with your request.
Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, see Authorized Agents below. We may request additional information so we may confirm a request to delete your personal information.
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 authorized representative. This may include:
- Provide us with the email address that you provided us to contact you at.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
Authorized Agents
You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days of its receipt. Our confirmation will include information about how we will process your request, including our verification process and when you may expect a response to your request. We will generally process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
Any we provide disclosures related to a Right to Know request will only cover the 12-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:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Websites that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. This includes our sharing of your personal information to third parties for their own direct marketing purposes when you accept cookies. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g. requests made this year will receive information regarding such activities for last year). You may request this information once per calendar year. To make such a request, please send an email to dataprotection@sharethrough.com or write us at: Legal Department, Sharethrough Inc. , 5455 Gaspe Avenue, Suite 730, Montreal; Quebec, Canada H2T 3B3.
Changes to This California Privacy Addendum
Sharethrough reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. 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 California Privacy Addendum, the ways in which Sharethrough collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact through the contact information provided in the Website Privacy Notice.
