CCPA PRIVACY NOTICE

Last Updated: January 1, 2020

General information

This CCPA Privacy Notice for California Residents (Privacy Notice) supplements the information contained in Hideez’s Privacy Policy (https://hideez.com/pages/privacy-policy).

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA), which has come into effect on January 1, 2020.

This notice applies to individuals residing in California from whom we collect Personal Information.

Hideez is complying with the CCPA and considering its underlying principles.

Information We Collect

We collect the information you provide us with when you use our Product, when you sign up for an account - registration in the Hideez system. We mean information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Your personal information may include for example your name, your contact details, or information on how you use our app or interact with us.

In addition, we collect information to help you with customer support issues. This information is usually legally required, such as when you are locked out of your account and need our assistance to regain access. To enhance your experience, we use cookies and related third party service providers and this use is based on your informed consent, which you may later withdraw.

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information and the information excluded from the CCPA’s scope.

More information about our specific practices can be found in our Privacy Policy.

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 disclose your personal information for a business purpose to the following categories of third parties: our affiliates, service providers with whom we have contractual relationships and third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide you with.

Per our policy, we have not sold, within the past twelve (12) months, any personal information.

Here are the categories of Personal Information that we have collected and/or disclosed for a business purpose in the preceding twelve (12) months:

Category	Examples	Collected	Disclosed	Sold
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.	YES	YES	NO
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, address, telephone number, passport number, driver's license or state identification card number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	YES	YES	NO
C. Protected classification characteristics under California or federal law.	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).	NO	NO	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	YES	NO
E. Biometric information.	Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	NO	NO
F. Internet or other similar network activity.	Browsing history and search history within our website; information on a consumer's interaction with a website and advertisement.	YES	YES	NO
G. Geolocation data.	Physical location or movements.	YES	YES	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	NO	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO	NO	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	NO	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	NO	NO

This information will be updated annually.

We obtain the personal information from the following sources:

directly from you (e.g. when you sign up for an account - registration in the Hideez system);

indirectly from you (e.g. observing your actions on our websites or in your account).

Use of Personal Information

According to the CCPA we collect, use and disclose the personal information for one or more of the following business purposes:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including processing payments.

To create, maintain, customize, and secure your account.

To communicate with you and manage our relationship with you; to provide you with email alerts and other notices concerning our products or services that may be of interest to you; to provide you with information, products or services that you request from us. Occasionally we may need to contact you by email for administrative or operational reasons, we may also send you app notifications for these purposes. Please, be aware that we can also use your information to send company and products updates as well as special offers. Your opinion is very important to us, so we may send you an email to seek your feedback. When using your personal information to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other electronic means.

To provide you with support and to respond to your inquiries, including restoring your account in case of loss. If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal information (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint based on anonymity. In case you lose your information about account that you created when registering in the Hideez system, we may use your personal information. We will need your e-mail address and (optionally) telephone number so that we may contact you if we have questions or information for you.

To improve our products or services and present its contents to you; to test, research, analyze and develop the product.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

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 with notice.

Your California Privacy Rights

If you are a California resident, you may exercise the following 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, we will disclose to you:

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 purposes for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.

Right to Deletion

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 a verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Please note that we may reject your request if retaining the information is necessary for us or our service providers to:

(1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.

(5) 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.

(6) 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 business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.

(8) Comply with a legal obligation.

(9) Otherwise, use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights, including, but not limited to, by:

(1) Denying goods or services to the consumer.

(2) Charging different prices or rates for goods or services, including using discounts or other benefits or imposing penalties.

(3) Providing a different level or quality of goods or services to the consumer.

(4) Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

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:

Calling us at +1(925) 5173231.

Emailing us at info@hideez.com.

Visiting us at https://hideez.com/pages/privacy-policy#modal-contact-us.

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 related to you.

We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (from 45 to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request receipt.

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.

Changes to this Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice posted on our website homepage.

Contact Information

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to info@hideez.com.