DataOwl CCPA

California Consumer Privacy Act Notice

1. About this Privacy Notice

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Dataowl LLC and its affiliates in scope of the CCPA (“Dataowl,” “we,” “us” or “our”) are providing this California Consumer Privacy Act Notice (“CCPA Notice”). This CCPA Notice supplements our Privacy Policy and applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the meaning ascribed to them in the CCPA.

2. Personal Information Collected

We collect 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, we have collected the following categories of personal information from consumers within the last twelve (12) months as indicated with a check mark below:

A. Identifiers such as a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.✓

B. Personal information as defined in the California customer records law, such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.✓

C. Characteristics of protected classifications under California or federal law such as 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).✓

D. Commercial information, such as transaction information, purchase history, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, financial details and payment information.✓

E. Biometric information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements.✓

G. Geolocation data, such as device location or movements.

H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.

I. Professional or employment-related information, such as job title as well as work history and experience or performance evaluations.

J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.

K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We collect the categories of personal information listed above from the following categories of sources:

Directly from our customers or their agents. For example, from documents or sources that our customers provide to us related to the services for which they engage us.
Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
Directly and indirectly from you when using our services or from activity on our Website. For example, from submissions through our Website or Website usage details collected automatically.
From third-parties that interact with us in connection with the services we perform.

We share this personal information with: our affiliates; our customers; our vendors, service providers, suppliers, agents and representatives; third-party data aggregation partners; and other parties where required by law or to protect our rights.

We may use this personal information to operate, manage, and maintain our business, to provide our products and services, to communicate with you, for data aggregation purposes, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: develop, improve, repair, and maintain our products and services; process or fulfill a request or other transactions submitted to us; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.

3. Personal Information Disclosed

In the preceding 12 months, we have disclosed and/or sold the following categories of personal information as indicated with a check mark below for a business purpose to our affiliates; our customers; our vendors, service providers, suppliers, agents and representatives; third-party data aggregation partners; and other parties where required by law or to protect our rights for our operational business purposes:

E. Biometric information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

G. Geolocation data, such as device location or movements.

H. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.

I. Professional or employment-related information, such as job title as well as work history and experience or performance evaluations.

J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.

K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

4. Consumer Rights

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, 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 purpose 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 (also called a data portability request).
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.

The above includes your right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

Do Not Sell My Personal Information

Under the CCPA, you have the right to opt out of the “sale” of your personal information. The CCPA broadens the definition of “sale” beyond how you might commonly interpret that term. Under the CCPA, the term “sell” is defined to include not just selling in exchange for money, but also sharing or transferring personal information in exchange for anything of value, which is not limited to the exchange of money. Certain things are not considered “sales,” including when (1) personal information is shared with a service provider that is contractually prohibited from using the personal information for any purpose beyond the service specifically requested, or (2) when the consumer has directed a company to disclose the personal information.

You can exercise this right by contacting us through this link: https://hellofyllo.com/do-not-sell-my-personal-information. Please note, some transfers of your personal information may not be considered “sales” and certain exemptions may apply under the CCPA. Your selection does not affect other sharing of your information, as outlined herein.

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, 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 providers 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 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.

You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

5. How to Make a Request

To make a request for the disclosures, “Do Not Sell” or deletion described above, please submit a verifiable consumer request by contacting us through this link https://hellofyllo.com/do-not-sell-my-personal-information, or by sending an email to privacy@hellofyllo.com.

Only you or a person registered with the California Secretary of State that you authorize 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:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
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.

Response Timing and Format

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or California Constitution.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 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.

6. Changes

We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.

Last updated: October 5, 2021