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Notice to California Residents (“Privacy Notice”)
TABLE OF CONTENTS
- The Kinds of Information We Collect
- How We Use Personal Information
- How We Share Personal Information
- Your Rights and Choices about What Personal Information We Collect and Maintain and How We Use It
- Glossary of Terms
- Changes to Our Privacy Notice
- Contact Information
1. The Kinds of Information We Collect.
On our website (“Our Site”), we collect information that, directly or indirectly, identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to, a particular visitor to Our Site (“Consumer”), who resides in the State of California (“Personal Information”). In particular, your Internet Protocol (IP) address is automatically collected when you visit Our Site. We also collect additional Personal Information about you when you visit Our Site and voluntarily provide that Information. Among the various types of Personal Information, the following are the categories of such Information, which we collect and have collected within the last twelve (12) months:
|A: Identifiers||Real names, email addresses, and Internet Protocol (IP) addresses.||YES|
|B: Personal information categories listed in California Customer Records statute (Cal. Civ. Code §1798.80(e))||Names, postal addresses, telephone numbers, and education or employment history.||YES|
|C: Protected classification characteristics under California or U.S. Federal law||Age (40 years or older), and sex (including gender, gender identity, gender expression and sexual orientation), military status, and genetic information.||YES|
|D: Commercial information||Products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.||YES|
|E: Biometric information||Genetic, physiological, or biological characteristics or activity patterns used to extract a template or other identifier or identifying information such as fingerprints, faceprints or voiceprints, iris or retina scans, keystroke gait or other physical patterns, or sleep, health or exercise data.||NO|
|F: Internet or other similar network activity||Browsing or search history, or information on consumer interaction with a website or advertisement||YES|
|G: Geolocation data||Generalized geolocation data extrapolated from IP Addresses||YES|
|H: Sensory data||Audio, electronic, visual thermal, olfactory or similar information||NO|
|I: Professional or employment-related information||Current or past job history or job title||YES|
|J: Non-public information (per the Family Educational Rights and privacy Act (20 U.S.C. §1232g, 34 C.F.R. Part 99))||Education records directly related to students and maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.||NO|
|K: Inferences drawn from other personal information||Content preferences or interests based on readership.||YES|
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the scope of the CCPA, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services, for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly or indirectly from activity on Our Site. For example, from submissions through Our Site portal or from usage details collected automatically on Our Site.
2. How We Use Personal Information.
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason, for which the information is provided. For example, the consumer providing Personal Information in connection with an inquiry about a possible franchise opportunity.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into with you, including for billing and collections.
- To improve the functionality and performance of Our Site for our users, including the delivery of information and other content to you and delivery of any goods and services you may request.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect (i) the rights, property or safety of us, our clients and other users of Our Site, (ii) the validity and reliability of the content on Our Site and any goods and services provided through that Site.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
3. How We Share Personal Information.
We may disclose your Personal Information to a third party for a business purpose (as defined in Section 6 below). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the third-party recipient to both keep that Personal Information confidential and not use it for any purpose except for the limited purpose of performing the contract.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our Affiliates (as defined in Section 6 below).
- Service Providers (as defined in Section 6 below).
- Third parties, to whom you or your agents authorize us to disclose your Personal Information, in connection with products or services we provide to you.
4. Your Rights and Choices about What Personal Information We Collect and Maintain and How We Use It.
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to You about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose (as defined in Section 6 below) for collecting or selling (as also defined in Section 6 below) that Personal Information.
- The categories of third parties, with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about YOU (also called a data portability request).
- If we sold (as defined in Section 6 below) or disclosed YOUR Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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 you request to have deleted 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 of 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 in order to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- If you had previously provided informed consent, 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 deletion of the Personal Information may likely render impossible or seriously impair the purpose(s) of that research.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with any legal obligation(s) we may have.
- Make other internal and lawful use of that Personal Information that is compatible with the context in which you provided that Information.
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 either:
- Calling us at the following toll-free telephone number: +1 (424) 383-7677
- Visiting us at www.entrepreneur.com/ccpa.
Only You or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
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 that the Personal Information relates 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 your identity as the person making the request or having your authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you in writing of the reason(s) why we will need more time and the additional time needed. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. The response we provide will also explain any reason(s) why we cannot comply with your request (if applicable). For data portability requests, we will select a format for providing your Personal Information which is readily usable and which should allow you to transmit that Information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Glossary of Terms.
As used in this Privacy Notice, the terms below shall have the following meanings:
“Affiliate” means a person or entity, who/which directly, or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with, us.
“Business purpose” under CCPA means the use of Personal Information for a business’ or service provider’s operational purpose(s) or other notified purpose(s), provided that the use of such information is reasonably necessary and proportionate to achieve the purpose for which the Personal Information was collected or processed or for another operational purpose that is compatible with the context in which the Personal Information was collected or processed. A business purpose includes: (i) auditing interactions with consumers such as counting ad impressions; (ii) security such as protecting against malicious or fraudulent activity; (iii) debugging such as identification and repair of impairments to functionality; (iv) short-term uses not involving disclosure to a third party, building a profile about a consumer, or altering a consumer’s experience outside of the transaction for which the personal information was collected; (v) performing services such as maintaining or servicing accounts and processing or fulfilling orders, verifying customer information, or providing advertising or marketing services; (vi) internal research for tech development; and (vi) quality and safety maintenance and verification.
“Commercial purpose” under CCPA means to induce a person’s commercial or economic interests, such as by inducing a person to buy, subscribe to, or provide goods, services or information.
“Sale” under CCPA means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information to a third party for valuable consideration or for no consideration, for the third party's commercial purposes.
“Service Provider” under the CCPA means a for-profit legal entity, to which we disclose a consumer’s Personal Information for processing for a business purpose pursuant to a written contract between us and the Service Provider.
7. Changes to Our Privacy Notice.
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage.
8. Contact Information.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Entrepreneur Media, Inc.
Toll-free Telephone No.: +1 (424) 383-7677
Postal Address: 18061 Fitch Avenue, Irvine, CA 92614