California Consumer Privacy Act
Notice to California Residents
Last Update: August 17, 2020
Information We Collect
Categories of Personal Information.
Sonobi has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the Last Update of this CCPA Notice (“Last Update”).
- Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, device ID or other similar identifiers.
- Commercial Information. Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, web browser, Internet Service Provider, or other similar information.
- Geolocation data.
- Inferences. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources.
We collect the Categories of Personal Information listed above from the following Categories of Sources: (i) directly from consumers (e.g., forms, surveys, responses, or other direct interactions from or with consumers), and (i) indirectly from consumers (e.g., consumer activity online, interactions with our Website, Service Providers, Clients, Client Advertisements, Client Digital Properties, and other sites).
Use of Personal Information.
Categories of Third Party Recipients.
We may share your Personal Information with the following Categories of Third Party Recipients for Business Purposes:
- Service Providers, including hosting services, technical assistance, database management/back-up services, data and usage analytics providers, Internet service providers, operating systems and platforms, email marketing platforms, and customer service.
- Promotional and Marketing Partners, which may include advertising, remarketing, data analytics or similar businesses, and participants in various programs offered by Sonobi.
Disclosures of Personal Information for a Business Purpose.
In the twelve (12) months preceding the Last Update, we may have disclosed or sold for a Business Purpose the Categories of Personal Information to the Categories of Third Parties set forth in Table I. In the twelve (12) months preceding the Last Update, we have not sold Personal Information.
|Categories of Personal Information Collected||Categories of Third Parties with Whom We Share this Personal Data for a Business Purpose||Categories of Third Parties with Whom We Sell this Personal Information for a Business Purpose|
Promotional and Marketing
|Commercial Information||Service Providers||Clients
Promotional and Marketing
|Internet or other similar network activity||Service Providers||Clients
Promotional and Marketing
|Geolocation data||Service Providers||
Promotional and Marketing
Promotional and Marketing
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.
Right to Know About Personal Information.
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 following (to the extent applicable to your request):
- Specific pieces of Personal Information we collected about you in the preceding twelve (12) months (also known as a data portability request)
- Categories of Personal Information we collected about you in the preceding twelve (12) months
- Categories of Sources from which the Personal Information was collected
- Our Business Purpose for collecting that Personal Information
- Categories of Personal Information we disclosed for a Business Purpose and the Categories of Third Party Recipients to whom the Personal Information was disclosed
Right to Request Deletion.
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.
Exercising Rights to Know or Request Deletion.
To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by either: (a) calling us at (800) 724-3080, or (b) submitting your request by email to email@example.com. You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) 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.
To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA. We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying 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.
Response Timing and Format.
We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar 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) calendar days of receipt of the request. We will deliver our written response by mail or electronically. 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.
Right to Opt-Out.
Sonobi provides multiple paths for you to opt-out regarding data collection, interest based advertising, sales of your Personal Information, and guidance regarding how to engage in other privacy controls such as access, portability and erasure.
Right to Opt-Out of Interest Based Advertising.
Publishers and advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to their privacy policies to learn more. Please note that Sonobi is not responsible for the privacy practices of its Clients, publishers, advertisers, and other third parties. Sonobi, and many of its partners, may provide you the option to opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s website and/or the Digital Advertising Alliance (DAA) website.
Please note that these opt outs only apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating advertisers, and the websites you visit may still collect information for other purposes.
Right to Opt-Out of the Sale of Personal Information.
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 clicking Do Not Sell My Information, completing and submitting the digital form, calling us at 800.724.3080 or by submitting your request via email at firstname.lastname@example.org.We will only use Personal Information provided in an opt-out request to review and comply with the request. 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 sending us an email with an opt-in request at email@example.com.
Right to Non-Discrimination.
We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CCPA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest 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 to know or delete your Personal Information 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 services or products marketed by those third parties.
To make such a request, please send an email to firstname.lastname@example.org.
Changes to Our CCPA Notice
This CCPA Notice is effective as of the date of the Last Update 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 or accessing the Website or the Services, purchasing products or services from us, or otherwise engaging or interacting with us 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.
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:
Phone: (386) 320-5400
Postal address: 444 W. New England Ave. Suite 220, Winter Park, FL 32789