We have collected the following categories of California Personal Information within the last 12 months from the sources listed below:
(a) Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties such as Linked Sites, your family and friends, Franchised Operators and Licensees, and public databases.
(b) Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, credit card number, debit card number, or other payment information. This category of information is collected from you, your devices, other CFA Group entities, Franchised Operators and Licensees or other third parties such as our business partners.
(c) Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. This category of information is collected from you when you choose to provide it to us directly or indirectly through our service providers and business partners as part of our surveys and market research.
(d) Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you, your devices, other CFA Group entities, Franchised Operators and Licensees or other third parties such as our business partners.
(e) Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a consumer’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
(f) Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
(g) Sensory data, including electronic, visual, or similar information. This category of information, such as photos, is collected from you and third parties such as Linked Sites, CFA Group entities, our service providers, or Franchised Operators and Licensees.
(h) Inferences, such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.
(i) Sensitive personal information, such as account login information allowing access to an account, precise geolocation data, race, and ethnicity, in each case as further described above in the relevant categories. If you win a promotional prize or sweepstakes, we may also collect your W9 information, including FEIN or SSN for legal compliance. Please note we do not collect sensitive personal information for the purpose of inferring characteristics about you.
For each of the above categories, we use the California Personal Information for a variety of purposes such as:
We may also use the information we collect for our operational purposes, purposes for which we provide you additional notice, provided that such additional purposes are compatible with the context in which the California Personal Information was collected, or with your consent.
Within the last 12 months, we have disclosed California Personal Information for our business purposes. To learn more about the categories of third parties with whom we share such information, please see the Section.
Your California Privacy Rights
If you are a California consumer, you have certain rights related to your California Personal Information, including:
You may request to exercise these rights by:
As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year, as applicable to the time period in which the CCPA was in effect.
The following details the metrics regarding consumer rights requests we received from all individuals, regardless of their state of residence, from January 1, 2022 to December 31, 2022.
Total Requests Received in 2022: 459
Granted (in whole or in part)
Median Days to Respond
Request to Know
Request to Delete
This California-specific addendum was last reviewed and updated as of January 1, 2024.
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