CALIFORNIA

PRIVACY NOTICE

FIRSTLY

As stated in our Privacy Policy, we would like to preface this California Privacy Notice with this: WE DO NOT SELL YOUR INFORMATION TO ANYONE FOR ANY REASON EVER. This means that we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us. More specifically, a “sale” of Personal Information under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal Information of a Consumer to another business or third party “for monetary or other valuable consideration.”

 

In this case, by way of example, not limitation, if browsing information stored in our Google Analytics account, including information we gathered from your IP address's activity, is used by Google Analytics to derive a better marketing tactic that we then use to improve our advertisement engagement, that could technically be considered "other valuable consideration." It is not "sold" in the traditional sense, as in for money, but it could be under the CCPA. Read on to see how this could affect you.

EFFECTIVE DATE: JANUARY 1, 2020

This notice reflects our good faith understanding of the California Consumer Privacy Act (the “CCPA”) and our data practices as of January 1, 2020, but the CCPA’s implementing regulations are not yet final, and there remain differing interpretations of the law. Accordingly, we may update information regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to TFR Beyouty LLC's ("TFR Beyouty, LLC," "TFR Beyouty," "TFRB," "we," "us", or “our”) other privacy policies or notices. In the event of a conflict between any other TFR Beyouty policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the California law. Please see also any general privacy policy or notice posted or referenced on our websites, apps, products, or services including, without limitation our online Privacy Policy.

This Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA for the twelve months preceding the Effective Date. If you are a California resident, the information below may apply to you in addition to our Privacy Policy. This Statement uses certain terms that have the meanings given to them by the California Consumer Privacy Act. 

COLLECTION AND DISCLOSURE

During the 12-month period prior to the effective date of this Addendum, we may have: 

Collected the following categories of personal information about you: 

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as customer number, unique pseudonym, or user alias), email address, account name, and other similar identifiers, physical characteristics or description, and signature

  • Identifiers (Online): a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers, and Internet Protocol address

  • Other Financial, Medical, and Health Information: bank account number, credit card number, debit card number, allergy information, and other financial information, medical information, and health insurance information

  • Information Related to Characteristics Protected Under California or Federal Law: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status

  • Commercial Information: including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies

  • Biometrics: biometric information gathered through biometric services that may or may not be offered at the present time (at the time of reading this)

  • Internet and Other Electronic Network Activity Information: including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

  • Geolocation Data

  • Sensory Information: Audio, electronic, visual, thermal, and similar information if knowingly submitted to us by you

  • Professional or Employment-Related Information

  • Education Information

  • Profile Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Collected personal information about you for the following business or commercial purposes: 

  • Performing services you have purchased from or contracted for with us, including maintaining or servicing accounts (e.g., your TFR Beyouty account), as well as providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

  • Detecting and responding to security incidents, protecting against and responding to malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

  • Debugging to identify and repair errors that impair existing intended functionality

  • Undertaking internal research for technological development and demonstration

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

  • Customizing your experience on our Platform

  • Processing liability claims

  • Complying with and enforcing applicable legal requirements, relevant industry standards and our policies

 

Shared your personal information with the following categories of third parties: 

  • Our affiliates

  • Our joint marketing partners

  • Our business partners

  • Social media networks

  • Third-party marketing partners

  • Government entities, including law enforcement as required by law

 

Sold (as defined under California law)

  • We may "sell" the following categories of personal information: 

    • Identifiers (online) associated with a device used to interact with our digital properties or advertisements (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology)

    • Internet and other electronic network activity information associated with a device used to interact with Digital Properties or advertisements

  • We do not sell, per CCPA (or any definition), the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.

 

Disclosed for a business purpose the following categories of personal information about you: 

  • Identifiers

  • Identifiers (Online)

  • Other Financial, Medical and Health Information

  • Information Related to Characteristics Protected Under California or Federal Law

  • Commercial Information

  • Biometrics

  • Internet and Other Electronic Network Activity Information

  • Geolocation Data

  • Sensory Information

  • Professional or Employment-Related Information

  • Education Information

  • Profile Inferences

 

CALIFORNIA CONSUMER PRIVACY RIGHTS 

You have certain choices regarding our use and disclosure of your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information related to you we have collected during the past 12 months. This may include:

    • The categories and specific pieces of personal information we have collected about you

    • The categories of sources from which we collected the personal information

    • The business or commercial purpose for which we collected or sold the personal information

    • The categories of third parties with whom we shared the personal information

    • The categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose

  • Deletion: You have the right to request that we delete certain personal information we have collected from you. Exceptions apply.

  • Opt-Out of Sale: You have the right to opt-out of the "sale" of your personal information.

  • Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

 

HOW TO SUBMIT A REQUEST

 

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you request access to or deletion of your personal information and do not sign in to an account with us, we require you to provide the following information: name, email address, phone number, and postal address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we reserve the option to require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right not to receive, and will not receive, discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. Employees and contractors are provided notice via different statements.

This Statement is available in alternative formats upon request. Please contact privacy@tfrbeyouty.com to request this Statement in an alternative format. 

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