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Privacy Notice for California Residents

Last updated: June 1, 2021

Emplifi understands the importance of your privacy and we take our responsibility to protect your information seriously.  This Privacy Notice for California Residents (“Notice”) supplements the information in the privacy policy posted on our website and applies solely to “consumers” as defined by the California Consumer Privacy Act of 2018 (“CCPA”).  This Notice explains our collection, processing, and disclosure of “personal information” relating to California consumers.  Specifically, this Notice applies to our processing activity when we are acting as a “business” under the CCPA—meaning that we control the purposes and means of processing your personal information.

In addition, due to our particular business, much of the personal information we collect and process is not subject to the CCPA.  For example, personal information we receive through business-to-business communications with consumers acting as representatives of another business is exempt from certain requirements under the CCPA.  Personal information that is subject to certain other data protection laws (such as the Fair Credit Reporting Act) may likewise be exempt from some or all of the requirements under the CCPA.  Accordingly, please read this Notice carefully before sharing information with us so you understand our practices regarding your information.

Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any 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 consumer, household, or device.  Personal information does not include:

  • Publicly available information from government records;

  • Deidentified or aggregated consumer information; and

  • Information excluded from the CCPA’s scope, including personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or the California Financial Information Privacy Act.

In the past 12 months, Emplifi has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for business purposes.

Category of PI Collected: Identifiers 

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. 

Categories of Third Parties to Whom Disclosed:

  • IT and cloud/hosting service providers, such as our email provider, business application providers, hosting providers, managed services providers and IT consultants 

  • Online analytics and marketing/advertising service providers 

  • Event hosting and registration service providers  

  • Financial institutions and payment processors

________

Category of PI Collected: Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

Examples: A name, signature, physical characteristics or description, address, telephone number. Some personal information included in this category may overlap with other categories. 

Categories of Third Parties to Whom Disclosed:

  • IT and cloud/hosting service providers, such as our email provider, business application providers, hosting providers, managed services providers and IT consultants

  • Marketing/advertising service providers

  • Event hosting and registration service providers

  • Financial institutions and payment processors

________

Category of PI Collected: Commercial information

Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Categories of Third Parties to Whom Disclosed:

  • IT and cloud/hosting service providers, such as our email provider, business application providers, hosting providers, managed services providers, and IT consultants

  • Marketing/advertising service providers

  • Financial institutions and payment processors

________

Category of PI Collected: Internet or other similar network activity

Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Categories of Third Parties to Whom Disclosed:

  • IT and cloud/hosting service providers.

  • Online analytics and marketing/advertising service providers

________

Category of PI Collected: Sensory data

Examples: Audio recordings, voicemail, or similar information.

Categories of Third Parties to Whom Disclosed:

  • IT and cloud/hosting service providers, such as our email provider, business application providers, hosting providers, and telephone communication providers

________

Emplifi collects these categories of personal information from the following sources:

  • Direct collection:  We collect information directly from you when you choose to provide it to us by filling out forms on our website, purchasing or registering to use any of our products or services on behalf of your organization, requesting a demo or a free trial of our products or services, signing up to receive promotional or information communications from us, attending an event or seminar we are putting on or sponsoring, creating an account or completing the details of any profile using our products or services, reporting a problem with our products or services, communicating with us, or otherwise directly providing the information to us.  

  • Collection via social media: We may collect personal data about social media platform users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.)The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.

  • Indirect and technology-based collection:  We also collect certain information from you indirectly when you visit, use, or navigate our website.  Emplifi collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in our website privacy policy.

  • Third-party collection:  From time-to-time, we may obtain invitee lists for events that we are co-hosting with other companies or in which we participate.

Use of Personal Information

We use the personal information we collect for the following business or commercial purposes (as well as any other purposes as set forth in our privacy policy):  

  • Provide our products and services to clients, including providing aggregated, anonymized data about the use of our website, social media content, and other digital interactions; 

  • Optimize your experience on our website and ensure that our content is presented to you in the most effective manner; 

  • Communicate with you and respond to your inquiries about our products and services and issues that may be relevant to you, including to provide you with promotional and informational communications regarding our products and services, notify you about our activities or events we are putting on or sponsoring, inform you about changes to our website or any products or services we offer, and investigate any concerns you have about our products and services; 

  • Research, develop, and improve our products and services, including by conducting client satisfaction surveys;  

  • Manage our business relationships with our clients, vendors, and suppliers, including carrying out our obligations and enforcing our rights arising from any agreements, processing invoices, and collecting payments; 

  • Protect and maintain the safety, security, and integrity of our products and services, our rights or property (including our website, databases, and other technology assets), to protect someone’s health, safety, or welfare, and to comply with a law or regulation, court order, or other legal process; 

  • Detect and identify any attempted fraud relating to our products or services; and

  • Perform other functions as otherwise described to you at the time of collection. 

Sale of Personal Information

In the past twelve (12) months, Emplifi has not sold personal information of any category.  Likewise, Emplifi does not have actual knowledge of any sales of personal information regarding minors under 16 years of age.   

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below.  For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable. 

1. Right to Request Information.  You have the right to request that we disclose certain information about our collection and use of your personal information during the past 12 months.  Specifically, you may request that we disclose:

  • The categories of personal information we collected about you;

  • The categories of sources for the personal information we collected about you;

  • The business and commercial purposes for collecting your personal information;

  • The categories of third parties with whom we shared your personal information;

  • The specific pieces of personal information we collected about you; and

  • If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.

2. Right to Data Portability.  You have the right to request that we provide copies of the specific pieces of personal information we collected about you.  If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically.  If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible.  Consistent with the CCPA and our interest in the security of your personal information, we will not provide copies of your Social Security number, driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers in response to a CCPA request, to the extent any of those items are in our possession.

3. Right to Request Deletion.  You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

Exercising Your Rights

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: dataprivacy@emplifi.io with the subject line: “CCPA Request” or calling us at +1-855-508-6150.  Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry, and the context in which we may have received your information. Please note that you may update your communication preferences by visiting https://go.emplifi.io/Communications-Preference-Center.html. If you are an agent submitting a request on behalf of a consumer, we may request that you submit signed permission from the consumer authorizing you to make the request.  In order to protect the privacy and data security of consumers, 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 of such consumer; and 

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.  We may also request that you provide additional information if needed to verify your identity or authority to make the request.  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 or the consumer on whose behalf you are making the request.  

Response Timing and Format

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days.  If we require more time, we will inform you of the reason and extension period in writing.  We will deliver our written response via e-mail.  Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another.  We will not charge a fee to process or respond to a 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 the request.  

Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:  

  • Denying you goods or services. 

  • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 

  • Providing you a different level or quality of goods or services. 

  • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time.  If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document.  Continued use of this website after any changes is deemed to be acceptance of those changes.  Please check this page periodically for updates.

Contact Information

If you have any questions or comments about this Notice, please contact us at.

Phone: +1-855-508-6150

Email: dataprivacy@emplifi.io

Postal Address:

Emplifi

Attn: Data Protection Officer

4400 Easton Commons, Suite 250

Columbus, OH 43219