CCPA Notice
Last Updated: December 18, 2019
This Pictalk CCPA Notice (“Notice”) is intended for all persons visiting the Platform who reside in the State of California (“consumers” or “you”) and is written in conjunction and incorporated into our Privacy Policy any capitalized terms that are not defined within this Notice can be found within our Privacy Policy. This Notice is pursuant to the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Platform collects the following personal information (defined under the CCPA):
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | Yes |
| G. Geolocation data. | Physical location or movements. | 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 performance evaluations. | Yes |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student 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. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes |
How We Collect Your Personal Information
The Platform may collect your personal information in the following ways: (1) directly from your submission of such personal information; (2) directly from another user; and/or (3) indirectly from your use of the Platform or observing your actions or interactions with other users.
Use of 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 you provided the personal information to us and to provide you with the full functionality and access to the Platform
- To use as disclosed with Section 4 of our Privacy Policy.
- To share with companies that we employ to provide services to the Platform.
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 notice.
Sharing Personal Information
Pictalk never sells your personal information to any third parties.
However, we may disclose your personal information to a third party for a business purpose, as required, so that we may provide you with access to the Platform, allow you to interact with the Platform, and to understand how you use our Platform. We have entered into agreements with all third parties that we disclose your personal information to and they are prohibited from selling such personal information.
We share your personal information with the following third parties:
- Google Analytics - policies.google.com/privacy
- Amazon Web Services - aws.amazon.com/privacy
- Stripe - stripe.com/privacy
- Sentry - sentry.io/privacy
Personal Information Requests
Under the CCPA you may request that we disclose to you the personal information and the types of personal information that we have collected from you in the past twelve (12) months and that we delete any/all personal information collected (unless an exception applies). Your personal information request may include the following:
- The specific personal information we have collected from you and a portable copy of such information.
- The categories of personal information and the source of such personal information we have collected.
- Our business purpose for collecting any personal information from you.
- The third parties with whom we share that personal information and the personal information disclosed to such third parties for a business purpose.
- Please remember that we never sell any of your personal information and never share any information with third parties except for the business purposes outlined within this Notice.
Please submit a verifiable Request to us by sending us a message via our Platform or at contact@pictalk.com with the message “CCPA Consumer Request” (“Request”) as the subject. You may make a Request for yourself or for your child that is under the age of eighteen (18). You may only make this Request twice per calendar year. The Request should include the following:
- Provide enough detail so that we may verify you are the actual person making the Request for any personal information or deletion of personal information requested.
- Provide enough detail within the Request and in accordance with the guidelines above so that we can properly verify, evaluate, and respond to your Request.
We do not charge any fees for such Requests unless permitted by the CCPA and we will notify you first before we charge you any fees related to such a Request.
Verifying and Responding to a Personal Information Request
Upon receipt of your Request we will attempt to verify that you are actually the person making the Request. Upon verification we will respond to your Request in a timely manner and in any event such Request response time will not exceed ninety (90) days and will be sent in an electronic format (unless requested otherwise).
Deletion Request Denial
We may deny a Request for deletion if retaining the information is necessary for us, our Platform, or any third party contractors as permitted under the CCPA. Where we deny a deletion request we will provide you with the reason as to the denial.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Updates to the Notice
We reserve the right to amend this Notice at any time and will update the date listed above. You must accept this Notice after each update or you may not continue using our Platform.
Contact Us
If you have any questions or comments about this Notice or your rights under the CCPA, please contact us at contact@pictalk.com.