PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Publish Date 8/3/2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of internalDrive, Inc. (“iD Tech”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit an iD Tech website, create an account, purchase an iD Tech product or your student participates in an iD Tech service/program (collectively, our “Services”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect
We may 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 person or device (“personal information”). In particular, we have collected the following categories of personal information from individuals that have visited our sites, purchased our products and applied for employment within the last twelve (12) months:

Examples of the type of information collected

Identifiers: Name, postal address, Internet Protocol address, email address, nickname, or other similar identifiers, personal meeting id.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Name, signature, address, telephone number, driver’s license or state identification card number,  education, employment, credit card number, credit card token, expiration date, CVV, or any other financial information, physical illness, mental illness or disabilities.allergies, immunizations, medications, social security number, ROuting number, financial institution name, account number, CPR certification information, social media memberships, spam tags, number of posts, date joined.

Protected classification characteristics: Age, ethnicity, race, physical illness, mental illness or disabilities, gender, veteran status

Commercial information: Purchase history

Internet or other similar network activity: Access history and information on your interaction with our pages including, type of browser used, Internet Service Providers (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us).  Cookies.

Professional or employment-related information: Occupation, employer information, experience

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 level, school attended, experience level

Geolocation data: Goelocation.

Audio, electronic, visual or similar information: Video recordings, telephone recording, profile pictures, photos 
 
We obtain the categories of personal information listed above from the following categories of sources:

 
II.    Use of Personal Information
We DO NOT SELL any personal information.  We may use or disclose the personal information we collect for one or more of the following business purposes:

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.

III.    Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. We engage certain trusted third parties to perform functions and provide services to us including, but not limited to hosting and maintenance, performance monitoring, billing, customer relationship, database storage and management, and direct marketing.  If we share your Personal Information with these parties, we only share information that is necessary to perform the function the third party was hired to provide.  We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:
You, your Agents, or non-profit partners with which you have an established relationship.

In the preceding twelve (12) months, we have not sold any personal information.

IV.    Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 A.    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 consumer request, we will disclose to you:

 
B.    Deletion Request Rights
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will 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 providers to:

C.    Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at privacy@idtech.com.

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 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:

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 consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

D.    Response Timing and Format
We will make every effort 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 the registered email associated with the 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 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.

E.    Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

V.    Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the top of this page. You are responsible for periodically visiting to check for any changes.

VI.     Contact Information
If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at CCPA@useindio.com.