California Consumer Privacy Act Notice
1. About this Privacy Notice
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Casters Holdings LLC dba Fyllo and its affiliates in scope of the CCPA (“Fyllo,” “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 December 13, 2021. 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.
Identifiers such as a real name, alias, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.✓
Personal information as defined in the California customer records law, such as name, telephone number, education, or employment information. Some personal information included in this category may overlap with other categories.✓
Characteristics of protected classifications under California or federal law such as age (40 years or older), race, national origin, marital status, gender, or military status.✓
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.✓
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.✓
Geolocation data, such as device location.✓
Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities.✓
Professional or employment-related information, such as job title as well as work history and experience or performance evaluations.✓
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 may collect the categories of personal information listed above from the following categories of sources: directly from our customers or their agents, indirectly from our customers or their agents in the course of providing our services, directly and indirectly from you when using our services or from activity on our website, data providers, advertising service providers, third parties that interact with us in connection with the services we perform, and third-party services that update or supplement information we hold about you.
We collect this information from you and our other users to measure and improve our Services and to administer our business activities, including fulfilling your requests, conducting research, developing new services, and offering additional products and services to our visitors. A more detailed description of these purposes is in our Privacy Policy under “Section 4. Use of Information We Collect.”
3. Personal Information Disclosed for Business Purposes
In the preceding twelve (12) months, we have disclosed for a business purpose the following categories of personal information as indicated with a check mark below to our affiliates; our vendors, service providers, suppliers, agents and representatives; third-party data aggregation partners; and other third parties as described in our Privacy Policy under “Section 5. Disclosure and Sharing of Information.”
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, or other similar identifiers.✓
Personal information as defined in the California customer records law, such as name, education, or employment information. Some personal information included in this category may overlap with other categories.✓
Characteristics of protected classifications under California or federal law such as age (40 years or older), race, national origin, marital status, gender, or military status.✓
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.✓
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.✓
Geolocation data, such as device location.✓
Professional or employment-related information, such as job title as well as work history and experience or performance evaluations.✓
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. Personal Information Sold
In the preceding twelve (12) months, we have sold the following categories of personal information as indicated with a check mark below to our affiliates; third-party data aggregation partners; and our customers, which include media companies including brands, advertising networks, distribution partners, third-party data enrichers, and marketing and advertising agencies:
Identifiers such as unique personal identifiers.✓
Personal information as defined in the California customer records law, such as education or employment information. Some personal information included in this category may overlap with other categories.✓
Characteristics of protected classifications under California or federal law such as age (40 years or older), race, national origin, marital status, gender, or military status.✓
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.✓
Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with other websites, applications, systems, and advertisements.✓
Geolocation data, such as device location.✓
Professional or employment-related information.✓
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.✓
5. 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 twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling your personal information.
The categories of third parties with whom we share your 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.
You also have the right to request that the information described above be provided to you in a portable and readily usable format, to the extent technically feasible (“data portability”).
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 our Do Not Sell link or by sending an email to privacy@hellofyllo.com with the subject line “Do Not Sell Info.” 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 and/or related to 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.
Non-Discrimination Rights
We may not, and will not, treat you differently because of your verifiable consumer request activity. As a result of your verifiable consumer request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level OR quality of goods or services, or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information.
General Exceptions to Consumer Rights
We may not fulfill requests if it would restrict our ability to:
Comply with federal, state, or local laws.
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
Cooperate with law enforcement agencies concerning conduct or activity that the business, service provider or third party reasonably and in good faith believes may violate federal, state, or local law.
Exercise or defend legal claims.
Collect, use, retain, sell, or disclose consumer information that is deidentified or in the aggregate consumer information.
Collect or sell a consumer’s information for commercial conduct that takes place entirely outside the state of California.
Use evidentiary privilege under California law.
6. Exercising your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, “Do Not Sell,” or deletion rights described above, please submit a verifiable consumer request by:
Contacting us via this link https://hellofyllo.com/do-not-sell-my-personal-information; or
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.
7. Verifying Requests
To help protect your privacy and maintain security, if you make a request to exercise your rights described above, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we may 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 a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).
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.
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.
8. Shine the Light Requests
California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by Company to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, please submit such request via this link: https://hellofyllo.com/do-not-sell-my-personal-information
9. Changes
We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.
10. Contact Us
If you have any questions, please feel free to contact us by email at privacy@hellofyllo.com or mail us at Fyllo, 404 W Harrison St. Suite 200, Chicago, IL 60607.
Last updated: December 13, 2021