BRANDCAST

California Consumer Privacy Rights Notice

Version effective 1 July 2020

This California Consumer Privacy Rights Notice (“Notice”) sets forth Brandcast, Inc.’s (“Brandcast”) disclosure obligations under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and the California Civil Code section 1798.83. This Notice provides the additional details regarding the information defined as ‘personal information’ under applicable California law and related to a California resident or household (“Consumers” and “You”) further referred to as “Personal Information.”

1. Personal Information Collected and Disclosed

Brandcast collects, uses and/or discloses Personal Information as follows:

Personal Information Collected, Used and/or Disclosed in Preceding 12 Months

CCPA Category

Collected?

Source of Collection

Business Purpose

Disclosed or Shared for Business Purpose?

Purpose of Disclosure

Category A: Identifiers & B Personal Information

- Name/Alias

Yes

You

Account Creation; Service Communications;

Yes; Service Providers

Data Security; Auditing; Services Communications; Payment Processing

- Email

Yes

You

Account Creation; Service Communications; Account Verification and Security

Yes; Service Providers

Data Security; Services Communications; Marketing

- Address

Yes

You

Payment Processing; Service Communications; Provide Requested Rate Services

Yes; Service Providers

Services Communications; Payment Processing; Marketing

- Cell or Telephone #

Yes

You

Service Communications; Marketing

Yes; Service Providers

Services Communications; Marketing

- Unique/Online ID (cookies)

Yes

Device

Program Analytics; Auditing; Data Security; ​ Marketing

Yes; Service Providers

Data Security; Marketing; Analytics

- IP Address

Yes

Device

Program Analytics; Auditing; Data Security

Yes; Service Providers

Data Security; Analytics

- Account Name

Yes

You

Data Security

N/A

N/A

- Social Security #

No

N/A

N/A

N/A

N/A

- Driver's License #

No

N/A

N/A

N/A

N/A

- Passport #

No

N/A

N/A

N/A

N/A

- Credit or Debit Card #/ACH

No

N/A

N/A

N/A

N/A

- Other: Medical/Financial/Health

No

N/A

N/A

N/A

N/A

Category C: Protected Characteristics

No

N/A

N/A

N/A

N/A

Category D: Commercial Information

- Personal Property Records

No

N/A

N/A

N/A

N/A

- Products/Services Purchased-Obtained-Considered

No

N/A

N/A

N/A

N/A

- Purchasing history/tendencies

No

N/A

N/A

N/A

N/A

Category E: Biometric Information

No

N/A

N/A

N/A

N/A

Category F: Internet/Network Activity

- Browsing/search history
- Interaction with site/adverstisement

No

N/A

N/A

N/A

N/A

Category G: Geolocation data

No

N/A

N/A

N/A

N/A

Category H:

- Audio

No

N/A

N/A

N/A

N/A

- Electronic

No

N/A

N/A

N/A

N/A

- Visual

No

N/A

N/A

N/A

N/A

- Thermal

No

N/A

N/A

N/A

N/A

- Olfactory

No

N/A

N/A

N/A

N/A

- Other Similar

No

N/A

N/A

N/A

N/A

Category I:
Professional/Employment-Related

No

N/A

N/A

N/A

N/A

Category J: Educational Information

No

N/A

N/A

N/A

N/A

Category K: Inferences from Data Collected

- Preferences

No

N/A

N/A

N/A

N/A

- Characteristics

No

N/A

N/A

N/A

N/A

- Psychological Trends

No

N/A

N/A

N/A

N/A

- Predispositions

No

N/A

N/A

N/A

N/A

- Behavior

No

N/A

N/A

N/A

N/A

- Attitudes

No

N/A

N/A

N/A

N/A

- Intelligence/Abilities/Aptitude

No

N/A

N/A

N/A

N/A

Other Potential Third Party Disclosures:

Personal Information may also be disclosed to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) as part of a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all or part of the business, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies as required by law; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations.

2. Your Consumer Rights under CCPA – Request to Opt Out of Sale of Personal Information

Brandcast does not sell any Personal Information collected from its Users.

3. Your Consumer Rights under CCPA – Right to Know, Right to Delete

California Consumers may contact Brandcast by email at legal@brandcast.com​ or through their account to request the following:

A. Request Brandcast Disclose at No Charge:

  • categories of Personal Information collected, used, and/or disclosed about you;
  • categories of sources from which Personal Information is collected;
  • business and/or commercial purposes for collecting and disclosing your Personal Information;
  • categories of third parties with whom your Personal Information has been disclosed/shared; and
  • the specific pieces of Personal Information collected about you.

B. Request Brandcast to Delete at No Charge:

Except as exempted pursuant to CCPA 1798.105, to request Brandcast delete Personal Information.

C. Verified Request Process:

Brandcast will confirm all consumer requests prior to taking any action in response to such request.

For account holders, Brandcast will initially verify through the existing authentication practices for your existing account. For non-account holders, Brandcast will initially verify through the email address maintained on file with the email address submitted in the applicable request.

Further verification will be based upon confirmation of data correlating to information maintained by Brandcast, as applicable.

Consumers may designate an authorized agent to make a request on the Consumer’s behalf at legal@brandcast.com. We will require that your authorized agent have written permission from you or other legal authority to make requests on your behalf and will need to verify the consumer and the authorized agent’s identity before processing any requests.

D. Consumer Request Limitations:

Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA, including, but not limited to:

  • Brandcast is obligated to disclose/delete only upon a verifiable​ Consumer request from the consumer or an authorized agent acting on behalf of Consumer.
  • Consumers may only make a personal information request twice in a 12-month period.
  • Deletion is not required because it is necessary for Brandcast to maintain the Personal Information to fulfill the purposes enumerated in CCPA Section 1798.105

Brandcast will confirm and respond to all requests within the timeframe required under the CCPA. In responding to any request to disclose/delete, Brandcast shall maintain a record of the requests as required under the CCPA.

4. Non-Discrimination Policy

You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA. Brandcast shall not discriminate against a consumer for exercising any rights under the CCPA, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates (including discounts/penalties) that is not directly related to the value provided to Brandcast for the Personal Information, (c) suggesting Consumer will receive a different rate/price or different level of quality of goods/services.

5. Your California Privacy Rights under California Civil Code Section 1798.83 & Business and Professions Code Section 22581

California law permits Consumers to request and obtain from once a year, free of charge, certain information about their Personally Identifiable Information (“PII”) (as defined by California law) disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of PII that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.

In addition, a business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

6. Accessibility of this CCPA Policy

You can download and print a copy of this Notice here.

7. Contact Us

Additional detail regarding our collection, use and disclosure of Personal Information, as well as general opt-out rights and other privacy disclosures, is set forth in our general Privacy Policy.

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: Brandcast, Attention Privacy: by email at legal@brandcast.com​ or by mail to 842 Folsom Street, San Francisco, CA 94107.

This Privacy Policy was last updated on December 22, 2020

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