PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“NOTICE”)
Last modified: April 18, 2020
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 or device (collectively, for purposes of the Notice, “CCPA Personal Information”). In particular, we have collected the following categories of CCPA Personal Information from consumers within the last twelve (12) months:
|A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|A name, address, telephone number, credit card number, debit card number, or any other financial information. Some CCPA Personal Information included in this category may overlap with other categories.
|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).
|D. Commercial information.
|Records of products or services purchased, obtained, or considered, or other purchasing histories.
|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.
|F. Internet or other similar network activity.
|Information on a consumer’s interaction with a mobile application, or advertisement.
|G. Geolocation data.
|Physical location or movements.
|H. Sensory data.
|Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
|Current or past job history or performance evaluations.
|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.
|K. Inferences drawn from other personal information.
|Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
CCPA Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, 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;
- CCPA 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 CCPA Personal Information listed above from the following categories of sources:
- Directly from our customers.
- Indirectly from our customers. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our Website (https://gabbanelli.com/).
Use of CCPA Personal Information
We may use or disclose the CCPA 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.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, 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 (or agreements) entered into between you and us, including for billing and collections.
- To improve our Mobile Application and/or Website.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your CCPA 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 CCPA Personal Information held by us is among the assets transferred.
We will not collect additional categories of CCPA Personal Information or use the CCPA Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you Notice.
Sharing CCPA Personal Information
We may disclose your CCPA Personal Information to a third party for a business purpose. When we disclose CCPA Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that CCPA Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of CCPA Personal Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records CCPA Personal Information categories.
Category D: Commercial Information
Category F: Internet and Website Activity and Mobile Application Activity
We disclose your CCPA Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your CCPA Personal Information in connection with products or services we provide to you.
In the twelve months prior to the effective date of this Notice, we has not sold any CCPA Personal Information of consumers, as those terms are defined under the CCPA.
Your Rights and Choices
The CCPA provides Consumers with specific rights regarding their CCPA 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 CCPA Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of CCPA Personal Information we collected about you.
- The categories of sources for the CCPA Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that CCPA Personal Information.
- The categories of third parties with whom we share that CCPA Personal Information.
- The specific pieces of CCPA Personal Information we collected about you.
- If we sold or disclosed your CCPA Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the CCPA Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the CCPA Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your CCPA 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 CCPA Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the CCPA 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 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 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.
- 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
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 CCPA 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 CCPA 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 CCPA Personal Information if we cannot verify your identity or authority to make the request and confirm the CCPA Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use CCPA Personal Information provided in a verifiable consumer request to verify the requestor’s identity or 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 of the reason and extension period in writing. 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 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 CCPA Personal Information that is readily useable and should allow you to transmit the 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 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.