CCPA Notice

California Consumer Privacy Act Notice

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California Consumer Privacy Act

Notice for California Residents

Last Updated: September 15, 2020

This Notice for California Residents (the “CCPA Notice”) supplements the Button, Inc. Privacy Policy (https://www.usebutton.com/privacy-policy), and applies solely to all natural persons who reside in the State of California (“consumers” or “you”), and visit or use our website located at http://www.usebutton.com (the “Website”), purchase products or services from Button, Inc. (together with all subsidiaries, “we” or “us”), or otherwise engage or interact with us. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms not otherwise defined in this CCPA Notice shall have the meaning assigned in the CCPA.

To the extent there is any conflict between this CCPA Notice and the provisions of the Privacy Policy, this CCPA Notice shall control only with respect to consumers and their Personal Information. If you are located outside of the State of California this CCPA Notice does not apply to you and you should refer to our Privacy Policy.

Scope of this CCPA Notice

Button is a business-to-business technology service provider to a marketplace of our clients (the “Button Marketplace”). Please note that the information below pertains solely to (i) your interactions with Button pursuant to your use of Button’s website (http://www.usebutton.com), and (ii) your interactions with Button as an employee, agent, or representative of one of Button’s customers. This CCPA Notice does not apply to your use of Button’s technology in the Button Marketplace. For more information on your rights regarding your personal information which is collected by our clients, please contact the relevant client(s).

Information We Collect

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, household, or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from or about consumers within the last twelve (12) months.

Table I -- Categories of Data (w/examples)

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e))

A name, signature, address, telephone number, or employment. Some Personal Information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law

None.

Commercial information

Products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.

Biometric Information

None.

Internet or other similar network activity

Information on a consumer’s interaction with a website.

Geolocation data

Physical location.

Sensory Data

None.

Professional employment-related information

Current position.

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 C.F.R. Part 99)

None.

Inferences drawn from other Personal Information

None.

Personal Information does not include:

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

We obtain the Categories of Data in Table I from the following Categories of Sources:

  • Directly from you. For example, from forms, surveys, responses, or other direct interactions from or with you, which you voluntarily complete and submit to us
  • Indirectly from you. For example, from observing your actions with regard to our products and services or on our Website and other websites.
  • Internet cookies/pixels.

Table II

Categories of Personal Information

Categories of Sources

Identifiers.

Directly from Consumer; Indirectly from Consumer.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Directly from Consumer; Indirectly from Consumer.

Protected classification characteristics under California or federal law.

n/a

Commercial information.

Indirectly from Consumer.

Biometric information.

n/a

Internet or other similar network activity.

Indirectly from Consumer; Internet cookies/pixels.

Geolocation data.

Directly from Consumer; Indirectly from Consumer; Internet cookies/pixels.

Sensory data.

n/a

Professional or employment-related information.

n/a

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C.Section 1232g, 34 C.F.R. Part 99)).

n/a

Inferences drawn from other personal information.

n/a

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

Table III -Category of Data

Business Purposes

Identifiers.

Marketing, Website Analytics

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Marketing, Website Analytics

Protected classification characteristics under California or federal law.

n/a

Commercial information.

Marketing, Website Analytics

Biometric information.

n/a

Internet or other similar network activity.

Marketing, Website Analytics

Geolocation data.

Marketing, Website Analytics

Sensory data.

n/a

Professional or employment-related information.

n/a

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

n/a

Inferences drawn from other personal information.

n/a

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 and obtaining your explicit consent.

Sharing Personal Information

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 keep that Personal Information confidential and not use it for any purpose except performing that contract.

We share your Personal Information with the following categories of recipients and third parties:

  • Service Providers

  • Affiliates

  • Data Analytics Providers

Table IV -

Categories of Personal Information

Categories of Recipients and Third Parties

Identifiers.

Service Providers, Affiliates, Data Analytics Providers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Service Providers, Affiliates, Data Analytics Providers

Protected classification characteristics under California or federal law.

n/a

Commercial information.

Service Providers, Affiliates, Data Analytics Providers

Biometric information.

n/a

Internet or other similar network activity.

Service Providers, Affiliates, Data Analytics Providers

Geolocation data.

Service Providers, Affiliates, Data Analytics Providers

Sensory data.

n/a

Professional or employment-related information.

n/a

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

n/a

Inferences drawn from other personal information.

n/a

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have not disclosed any Personal Information for a business purpose.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold Personal Information.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you:

  • The categories of Personal Information we collected about you

  • The categories of sources for the Personal Information that we have collected about you

  • Our business or commercial purpose for collecting that Personal Information

  • The categories of third parties with whom we share that Personal Information

  • The specific pieces of Personal Information we have collected about you (also called a data portability request)

Deletion Request Rights

You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your 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 Personal 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 or 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 that 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 et. 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; or

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 emailing privacy@usebutton.com or calling us at (866) 686-7357.

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 related 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.

Verification Process

To verify a consumer request hereunder, we may ask questions and request certain information from you.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law.

If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

However, if a consumer request that seeks disclosure of specific pieces of Personal Information is denied because we cannot verify the identity of the person making the request under the applicable verification rules under the CCPA, then we shall treat the request as one that seeks the disclosure of the categories of Personal Information and apply the verification rules in the CCPA applicable to requests for disclosure of categories of Personal Information.

If a consumer request that seeks disclosure of categories of Personal Information is denied because we cannot verify the identity of the person making the request under the applicable verification rules in the CCPA regulation, then we shall provide or direct the requestor to our general business practices regarding the collection, maintenance and sale of Personal Information as set forth in this Privacy Policy.

Response Timing and Format

We will confirm receipt of a verifiable consumer request within ten (10) days of its receipt.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) days of receipt of the request.

We will deliver our written response by mail or electronically, at your option. If you do not have an account with us, and you do not indicate a preference for delivery, we will use its discretion in choosing the method of delivery of the information.

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 may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”). We do not knowingly sell the Personal Information of children under the age of 16, unless we receive affirmative authorization (the “right to opt-in”) from either (i) the consumer who is between 13 and 16 years of age, or (ii) the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing privacy@usebutton.com.

Once you make an opt-out request, we will not ask you to reauthorize Personal Information sales for at least twelve (12) months. However, you may change your mind and opt back in to Personal Information sales at any time by emailing privacy@usebutton.com

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

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

  • Denying you products or services

  • Charging you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.

  • Providing you a different level or quality of products or services

  • Suggesting that you may receive a different price or rate for products or services or a different level or quality of products or services

Right to Designate an Authorized Agent

If you submit a request for access and portability or deletion through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

Other California Privacy Rights

Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of Research Activities or products marketed by those third parties.

To make such a request, please send an email to privacy@usebutton.com or write us at:

Button, Inc.
Attn: Data Protection Officer
PO Box 8176
PMB 90775
Greenwich, CT 06836-8021

Changes to Our CCPA Notice

This CCPA Notice is effective as of the ‘Effective Date’ date stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting the Website or continuing to do business with Button after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

E-mail:
privacy@usebutton.com

Postal address:
Button, Inc.
Attn: Data Protection Officer
PO Box 8176
PMB 90775
Greenwich, CT 06836-8021

Phone:
(866) 686-7357

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