Effective Date: January 1, 2020
Last Reviewed: April 14, 2020
This Privacy Notice for California Residents (“Notice”) supplements the information contained in X2X, LLC, its affiliates, and its subsidiaries (collectively “X2X” or “we”) privacy policy (”Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“users” or “you”). We adopt this Notice in conformity with California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household, or device (“Personal Information”). Personal Information does not include:
- Publicly available information from government records;
- Deidentified or aggregated user information;
- Information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPPA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Report Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
In particular, We have collected within the last twelve (12) months and continue collecting, unless otherwise requested by you, the following categories of Personal Information from our users:
| Category |
Examples |
Collected |
|
A real name, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
YES |
| 2. |
Personal Information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)). |
|
A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information.
Some Personal Information included in this category may overlap with other categories or may not be applicable to X2X. |
NO |
| 3. |
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). |
NO |
| 4. |
Commercial information |
|
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
NO |
|
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 patters and sleep, health, or exercise data. |
NO |
| 6. |
Internet or other similar network activity |
|
Information on a user’s interaction with a website, application, or advertisement. |
YES |
|
Approximate physical location derived from the IP address. |
YES |
|
Audio, electronic, visual, thermal, or similar information |
NO |
| 9. |
Professional or employment-related information |
|
Current or past job history or performance evaluations |
NO |
| 10. |
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 |
| 11. |
Inferences drawn from other personal information |
|
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
N0 |
| Examples |
| A real name, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. |
| Category |
| 2. |
Personal Information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)). |
|
| Examples |
A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information.
Some Personal Information included in this category may overlap with other categories or may not be applicable to X2X. |
| Category |
| 3. |
Protected classification characteristics under California or federal law |
|
| Examples |
| 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). |
| Category |
| 4. |
Commercial information |
|
| Examples |
| Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| Examples |
| 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 patters and sleep, health, or exercise data. |
| Category |
| 6. |
Internet or other similar network activity |
|
| Examples |
| Information on a user’s interaction with a website, application, or advertisement. |
| Examples |
| Approximate physical location derived from the IP address. |
| Examples |
| Audio, electronic, visual, thermal, or similar information |
| Category |
| 9. |
Professional or employment-related information |
|
| Examples |
| Current or past job history or performance evaluations |
| Category |
| 10. |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) |
|
| Examples |
| 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. |
| Category |
| 11. |
Inferences drawn from other personal information |
|
| Examples |
| Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
We collect the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products or services you purchase;
- Indirectly from you. For example, from observing your actions on X2X’s website and/or your use of our products and services;
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your request. We may also save your information to facilitate new orders or service requests.
- To provide, support, personalize, and develop our products and services.
- To create, maintain, customize, and secure your account with us.
- To provide you with support and to respond to your inquiries, including investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
- 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 about our users is among the assets transferred.
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
We may disclose your Personal Information to a third party for a business purpose. When we disclose such Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We share your Personal Information with the following categories of third parties:
- Service providers.
- Affiliates and subsidiaries.
Disclosure of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information solely for a business purpose:
- Category 1: Identifiers
- Category 7: Geolocation data
We disclose your Personal Information solely for a business purpose to the following categories of third parties:
- Service providers
- Affiliates and subsidiaries
Sale of Personal Information
In the preceding twelve (12) months, X2X had not sold Personal Information and does not sell your Personal Information as defined under CCPA.
Your Rights and Choices
The CCPA provides users (California residents) with specific rights regarding their Personal Information as explained below in this Section.
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 user 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 for collecting 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 disclosed your Personal Information for a business purpose, a separate list disclosing the disclosures for a business purpose, identifying the Personal Information categories that each category 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 user 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 information is necessary for us or our service provider(s) 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, fulfill the terms or a written warranty or product recall conducted in accordance with federal law, 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.
- Comply with the California Electronic Communication Privacy Act (Cal. Penal Code §1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with user expectations based on your relationship with us.
- Comply with a legal obligation including fulfillment of contractual obligations.
- 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
To exercise the access, data portability, and deletion rights described above, please submit a verifiable user request to us by e-mailing us at privacy@x2x.media.
Only you, or someone legally authorized to act on your behalf, may make a verifiable user request related to your Personal Information. You may also make a verifiable user request on your minor child.
The verifiable user 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; and
- 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 relates to you.
Making a verifiable user request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable user request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond via e-mail to a verifiable user request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable user request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, based on our technical abilities and resources, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable user 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.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny your 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 of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.
Changes to our Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s last reviewed date. Your continued use of our website, products, and/or services following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about the Notice, the ways in which X2X collects and uses your information described here (and in the Privacy Policy), your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: privacy@x2x.media
Mailing Address: 100 1st St #300, San Francisco, CA 94105, USA
