California Consumer Privacy Act (CCPA) and California Consumer Privacy Rights Act (CPRA)
Notice for California Consumers
Dated July 2023
Overview
The California Consumer Privacy Act of 2018 (the “CCPA”) became effective on January 1, 2020 and was amended to a certain extent by the California Consumer Privacy Rights Act (“CPRA”, and together with the CCPA, “California Privacy Regulations”) which came into effect on January 1, 2023 and created a variety of privacy rights for California residents. We share the same information about our practices with everyone but use this notice to make relevant disclosures required by California Privacy Regulations. This notice includes the following parts:
Transparency: We are transparent about how your personal information is collected, used, shared and sold.
Control: We put you in control of your personal information, including accessing and deleting your personal information.
Benefits to You: We use your personal information to benefit you and to make your experience better.
You have the right to know what kinds of personal information Anduin is collecting about you, how we collect it and our business or commercial reasons for that collection.
We make this information available to consumers in the “Information Collected” and “Automated Information Collection” sections of our Privacy Policy.
How We Use and Share Your Personal Information
You have the right to know how personal information is used and our business or commercial reasons for that use. You have the right to know if your personal information is shared by us with any third parties. We may share personal information with Service Providers, as defined by the CCPA, to perform services specified by written contract. In addition, we may share personal information with third parties for other notified purposes, as permitted by California Privacy Regulations.
We make this information available to consumers in the “Usage and Disclosure of Information” section of our Privacy Policy.
We Do Not Sell Your Personal Information
You have the right to know whether your personal information is being sold. Your personal information is “sold” when it is shared with a third party for monetary or other valuable consideration for something other than a “business purpose” as set forth in the CCPA.
Anduin does not sell your personal information.
Control
Right to Receive, Obtain and Delete
You have the right to:
Receive what specific pieces of personal information Anduin has collected, retained, disclosed or sold about you over the previous 12 months.
Obtain a copy of your personal information held by us.
Request that we Delete your personal information.
Request that we Correct any inaccurate personal information held by us.
Limit the Use and Disclosure of Sensitive Personal Information (“SPI”)1.
Anduin makes it easy for you to exercise your rights. You can contact us by email atcontact@anduintransact.com. Before helping you with your inquiry, we may ask to verify your identity or the identity of your authorized agent.
Right to “Opt-out” of “Sale”
Anduin does not sell your personal information, so we do not offer an opt-out.
Benefits to You
Financial Incentives
California Privacy Regulations allow businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information. Where Anduin offers these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
Non-Discrimination
California Privacy Regulations prohibit businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. California Privacy Regulations permit businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.
1 This right is limited by our right to collect, use or disclose such SPI which is necessary and proportionate:
to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
to prevent, detect, and investigate security incidents that compromise PI;
to resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions;
to ensure the physical safety of natural persons;
for short-term and transient use, provided that the personal information is not disclosed to another third party and is not used for target advertising outside the consumer’s current
interaction with the business;
to perform services on behalf of the business;
to verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business; or
to collect or process SPI where such collection or processing is not for the purpose of inferring characteristics about a consumer.
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