Addendum for California Residents: California Privacy Rights

Effective:  January 1, 2023

NOTICE TO CALIFORNIA RESIDENTS [CONSUMERS] - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. To the extent that SafeGraph is subject to the CCPA, this section of the Privacy Policy articulates the policies for natural persons who are residents of California (“California Consumer”) and whose Information SafeGraph may collect. This Addendum supplements the information in the Privacy Policy. However, this Addendum is intended solely for, and is applicable only as to, California Consumers. If you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it. The term “Information” as used in this Addendum has the same meaning as “personal information” under the CCPA. 

In the below tables and sections, we describe (as required by the CCPA):

  1. Notice at Collection – the categories of Information that we collect directly from you, the purpose of the collection, the categories of sources we collect it from, and the period for which we retain that Information.
  2. The Information Collected, Sold, Shared, or Disclosed in the past twelve months. 
  3. Your California Privacy Rights and Choices – what rights you have under the CCPA, for instance, to request that we “opt out” your information from our marketing database (also called “do not sell” rights), or to request categories and personal information that we may have collected about you.

1. Notice at collection of personal information

Depending on how you interact with us, the table below summarizes the categories of Information we may directly collect about you and whether we sell or share that information:

Category
Sold or Shared
Identifiers
E.g.,  IP address; mobile ad identifiers.
IdentifiersE.g., IP addresses; the names, addresses, phone numbers, etc. of our customers and prospective customers, business partners or employment candidates.
No.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
No.
Characteristics of protected classifications under California or federal law (e.g., gender of potential customers in marketing surveys).
No.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No.
Internet or other electronic network activity information.
No.
Professional or employment-related information.
No.

Purposes: We collect this Information for the following purposes:

1. Marketing, analytics, and other research, for example:

  • to respond to communications and customer service inquiries;
  • to market to you and provide you information about new products and events;
  • for our internal and operational purposes, such as to consider or make internal service improvements or quality checking, or for our own sales and marketing purposes.

2. Processing job applications and employee management.

3. Other internal purposes, for example:

  • internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use Site Data, from other “business to business” interactions (such as at trade shows) or from data compilers for the above, as well as for our own marketing, business and employee recruitment purposes.

Retention: We retain your Information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain your Information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and/or accounting requirements set by a legislature, regulator or other government authority.

2. Notice of Collection, Sale, Sharing, and Disclosure of Information in Past 12 Months

During the past twelve months we have collected the following Information for the following business and commercial purposes from the following categories of sources:

Category
Sold or Shared
Included in SafeGraph Services?
Business or Commercial Purpose
Identifiers
E.g., IP addresses; the names, addresses, phone numbers, etc. of our customers and prospective customers, business partners or employment candidates.
You, analytics providers, advertising networks and platforms
No.
See Purposes in Section 1 above
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
You, analytics providers, advertising networks and platforms
No.
See Purposes in Section 1 above
Protected classification characteristics under California or federal law.
You, analytics providers, advertising networks and platforms
No.
See Purposes in Section 1 above
Geolocation Data.
Third Party Data Compilers
No.
To develop SafeGraph Services
Internet or other electronic network activity information.
Analytics providers, advertising networks and platforms
No.
See Purposes in Section 1 above
Professional or employment-related information.
You, recruiters, and executive search agencies
No.
See Purposes in Section 1 above
Sensitive Personal Information (e.g. precise geolocation data)
To the extent we collection sensitive information, we do not use it to infer characteristics about a consumer, consistent with section 1798.121(d).
Third Party Data Compilers
No.
To develop SafeGraph Services

During the past twelve months, we have not sold Information or shared  Information for cross-context behavioral advertising.

During the past twelve months, we have disclosed the following Information to third parties for the following business and commercial purposes:

Category
Category of Third Parties to Whom Disclosed
Business or Commercial Purpose
Identifiers
E.g., IP addresses; the names, addresses, phone numbers, etc. of our customers and prospective customers, business partners or employment candidates
To service providers for the provision of services to SafeGraph.
Marketing, analytics, and other research
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
To service providers for the provision of services to SafeGraph; to government regulators as required by law
Marketing, analytics, and other research
Professional or employment-related information.
To service providers for the provision of services to SafeGraph; to government regulators as required by law
Processing job applications and employee management

3. Your California Rights and Choices

Without being discriminated against for exercising these rights, California Consumers have the right to request that we disclose what Information we collect from you, to correct that Information, to delete that Information, to opt-out of the sale or sharing of your Information, and to limit the use and disclosure of sensitive personal information subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a “business” (as opposed to a “service provider”) for purposes of handling Information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)

Right to Know: California residents have the right to know what Information we have collected about them and the right to request that we provide them certain information about how we have handled their information in the prior 12 months, including the:

  • categories of Information collected;
  • categories of sources of Information;
  • categories of Information about them we have disclosed for a business purpose or sold;
  • categories of third parties to whom we have sold or disclosed for a business purpose their Information;
  • the business or commercial purposes for collecting or selling their Information; and
  • a copy of the specific pieces of Information we have collected about them.

Right to Deletion: California Consumers have the right to request deletion of their Information that we have collected about them, subject to certain exemptions, and to have such Information deleted, except where necessary for any list of exempt purposes. Please also note that we may retain Information for certain important purposes, such as (a) to protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality (such as de-bugging purposes), (c) as necessary for us, or others, to exercise their free speech or other rights, (d) to comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services

Right to Correct: California Consumers have the right to correct inaccurate Information that a business maintains about that consumer.

Notice of Right To Opt-out of the Sale or Sharing of Information: California Consumers have the right to opt-out of the sale of their Information or the sharing of their Information for cross-context behavioral advertising.  Please note that SafeGraph does not sell Information or engage in cross-contextual behavioral advertising.  

Notice of Right to Limit Use and Disclosure of Sensitive Personal Information: California Consumers have the right to limit the use and disclosure of their sensitive personal information if used or disclosed for purposes not specified in the CCPA.  

Right to Non-discrimination. California Consumers have the right not to be subject to discriminatory treatment for exercising their privacy rights under the CCPA, including the right not to be retaliated against for the exercise of their CCPA rights.

4. Information About Persons Under 16 Years of Age  

We do not knowingly collect Information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent).

5. Methods for Exercising Opt-Out Rights

You have the right to opt-out of the sharing of your Personal Information by us or to limit the use or disclosure of your Sensitive Personal Information.  To exercise these rights, you can use the link https://www.safegraph.com/do-not-sell-my-info on our website or send an email to [email protected].

6. Verification of Requests

Please note that we may require additional information from you in order to verify your request.

We will need to verify your identity to respond to Requests to Know, Requests to Correct and Requests to Delete. Depending on the nature of the request and the Personal Information that is the subject of the request, we may request two or more pieces of Personal Information for the purpose of verifying the consumer together with a signed declaration under penalty of perjury that the requestor is the consumer whose Personal Information is the subject of the request.  

There may be circumstances where we will not be able to honor your request. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. However, we will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

7. Authorized Agent

As a California Consumer, you have the right to designate an agent to exercise these rights on your behalf.  In such a cases, we may require you to do either of the following: (1) verify your own identity directly with us or (2) directly confirm with us that you have provided the authorized agent permission to submit the request. Alternatively, you or your authorized agent can provide us a power of attorney pursuant to Probate Code sections 4121 to 4130. Please contact us at [email protected] for more information if you wish to submit a request through an authorized agent.

8. Contact Us

If you have questions about our privacy policies or practices or this Addendum, please contact us at [email protected].

9. “Shine the Light.”

California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to [email protected].  You may only make one such request per calendar year.