California Privacy Notice
Effective Date: December 1, 2023
This California Privacy Notice (“Notice”) supplements our general Privacy Notice and applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act (collectively, the “CCPA”). Any capitalized or defined terms not separately defined in this Notice shall have the meanings given to those terms in our Privacy Notice or in the CCPA.
This Notice also serves as our Notice at Collection for purposes of the CCPA
1. Scope
Please note that this Notice only applies to the extent that we are a “Business” in relation to the processing of your Personal Information. In some cases, we process Personal Information as a “Service Provider” or “Contractor” to our Clients, and this Notice may not apply. In those situations, you may be required to reach out to our Clients directly to learn more about your privacy rights.
You can learn more about the Sites and Services covered under this Notice by reviewing our general Privacy Notice.
2. Personal Information We Collect About California Consumers
We describe the Personal Information we have collected about consumers in the twelve (12) months preceding the effective date of this Privacy Notice in the part of our Privacy Notice titled, “Personal Information Collected” above. The information we collect includes the following:
| Category of Personal Information Collected | Collected (Yes/No) | Sources of Personal Information Collected | Business or Commercial Purpose for Collection |
| Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above. | Yes | You Automatically Third Parties | To provide our products and Services To provide information you requested To improve our products and Services To identify potential customers To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To offer employment, to provide insurance and benefits, for background checks |
| The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. | Yes | You Automatically Third Parties | To provide our products and Services To provide information you requested To improve our products and Services To identify potential clients To market our products and Services For verifying identityFor fraud prevention purposes To process payments To comply with law To manage payroll and provide and administer employee benefits |
| Characteristics of protected classifications under California or federal law list any of these that you collect: 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. | Yes | You Automatically Third Parties | To provide our products and Services to Clients To improve our products and Services To offer employment, to provide insurance and benefits, for background checks To comply with law |
| Commercial information, including information about orders or purchases of any of our Services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. | Yes | You Automatically Third Parties | To provide our products and Services To market our products and Services To improve our products and Services To provide information you requested To comply with law |
| Biometric data. | N/A | N/A | N/A |
| Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, mobile apps, advertisements that we display on the Site or mobile apps or on third party websites and apps, or Tinuiti pages or accounts on any third-party social media platforms. | Yes | You Automatically Third Parties | To provide our products and services To market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes |
| Geolocation data. | Yes | Automatically | To market our products and services For detecting security incidents and protecting our Site |
| Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above. | No | N/A | To provide our products and Services |
| Professional or employment-related information | Yes | Automatically | To provide our products and Services To offer employment, to provide insurance and benefits, for background checks |
| Education information | Yes | You Automatically | To provide our products and Services. To offer employment to provide insurance and benefits for background checks. |
| Inferences drawn from (1) the information we collect when you visit the Site, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on the Site and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. | Yes | You Automatically Third Parties | To provide our products and Services To market our products and Services To improve our products and Services For detecting security incidents and protecting our Site |
| Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number. | Yes | You | N/A |
We collect this Personal Information from sources that include our Clients and other sources referenced in the “Personal Information Collected” section above.
3. Disclosure, Sale, or Sharing of Personal Information
Under the CCPA, the disclosure of Personal Information that is necessary to provide you with personalized ads and with some of our partners may be considered “selling” or “sharing”, even if no money is exchanged. In that respect, we may disclose email addresses and contact information to other businesses and third parties that include our joint marketing partners when we host webinars and events with them within the twelve (12) months preceding the effective date of this Privacy Notice.
In addition, Tinuiti may purchase, use, and share for commercial purposes consumer data across consumer devices to deliver advertising via our proprietary graph-matching technology. As is common practice among businesses that operate websites, we may also disclose certain online identifiers, information about the use of the Site, and inferences drawn about you to our social media, advertising, and analytics partners.
| Category | Categories of Third Parties We Share With | Whether We “Sold” This Category of Personal Information in the Last 12 Months |
| 1. Identifiers such as name, address, email address, phone number. | Advertising partners Analytics providers Media platforms Clients (and their service providers) Social media networks Consumer data resellers Distribution partners | Yes |
| 2. The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. | N/A | No |
| 3. Characteristics of protected classifications under California or federal law | Advertising partners Analytics providers Media platforms Clients (and their service providers) Social media networks Consumer data resellers Distribution partners | Yes |
| 4. Commercial information, including information about orders or purchases of any of our Services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. | N/A | No |
| 5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the Site, mobile apps, advertisements that we display on the Site or mobile apps or on third party websites and apps, or Response Media pages or accounts on any third-party social media platforms. | Advertising partners Analytics providers Media platforms Clients (and their service providers) Social media networks Consumer data resellers Distribution partners | Yes |
| 6. Geolocation data. | Advertising partners Analytics providers Media platforms Clients (and their service providers) Social media networks Consumer data resellers Distribution partners | Yes |
| 7. Audio information from calls placed with customer service that may be reported, and electronic information in the form of Internet or other electronic network activity information described above. | N/A | No |
| 8. Professional or employment-related information | N/A | No |
| 9. Education information | N/A | No |
| 10. Inferences drawn from (1) the information we collect when you visit the Site, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on the Site and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. | Advertising partners Analytics providers Media platforms Clients (and their service providers) Social media networks Consumer data resellers Distribution partners | Yes |
| 11. Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number. | N/A | No |
We have disclosed, sold, or, shared (within the meaning of the CCPA) Personal Information in all or substantially all of the categories identified above for various business or commercial purposes, including the purposes for collection identified in Section 1 above or for any purpose identified in our Privacy Notice. Additionally, along with the entities identified above, we may have disclosed the Personal Information identified in Section 1 to our own Service Providers or Contractors for our business purposes. For information regarding the purposes for which we collect and use the Personal Information we collect, please see the “Use of Your Information” and “How We Share and Disclose Your Information” sections in our general Privacy Notice.
We do not have actual knowledge that we sell or share the Personal Information of California residents under the age of 16.
4. Your Rights
If you are a California resident, you may have certain rights in relation to the processing of your Personal Information. These may include the following:
Right to Know and Access Personal Information
You have the right to request, no more than twice in a 12-month period, that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information is collected;
- Our business or commercial purpose for collecting, selling, or sharing Personal Information;
- The categories of third parties with whom we share Personal Information;
- The specific pieces of information we have collected about you;
- The categories of Personal Information about you, if any, that we have sold or shared, and for each category identified, the categories of third parties to whom we sold or shared that particular category of Personal Information;
- The categories of Personal Information about you that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information.
We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within forty-five (45) days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you through your account, if you maintain an account with us, or electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hinderance. If we receive a Right to Know request regarding information that we process on behalf of our Client, we will also recommend that the California resident submit a Right to Know request directly with the client, and will provide contact information for that client where feasible.
Right to Deletion of Personal Information
You have the right to request that we delete Personal Information about you that we have collected from you. If we are able to verify your identity or the identity of your authorized agent, we will respond to your request by deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information.
We may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information. We will specify the manner in which we delete your Personal Information. If a California resident submits a request to delete Personal Information to one of our Clients and the Client instructs us to delete the California resident’s Personal Information, we will delete the information as required by the CCPA. If we receive a Right to Deletion request regarding information that we process on behalf of our client, we will also recommend that the California resident submit a Right to Deletion request directly with the Client and will provide contact information for that Client where feasible.
In some situations and as permitted by the CCPA, we may not be able to process your request to delete if we need to maintain your information for some legally permissible purpose (e.g., to comply with our legal obligations). We will let you know if we are unable to process your request.
Right to Correct Personal Information
You have the right to request that we correct any inaccurate information that we maintain about you.
Right to Opt Out of Sale or Sharing
You have the right to opt-out of the “sale” or “sharing” of your Personal Information, as those terms are defined in the CCPA. To Opt-Out, click this link.
Right to Limit the Use of Your Sensitive Personal Information
You have the right to limit our use of your sensitive Personal Information to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations. We do not collect, use, or disclose your sensitive Personal Information for purposes other than those listed in § 7027(m).
Right to Non-Discrimination
We may not discriminate against you because you have exercised any of the foregoing rights, including by:
- Denying you our Services;
- Charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of our Services; or
- Suggesting that you will receive a different price or rate for our Services or a different level or quality of our Services.
However, we may charge different prices or rates, or provide a different level or quality of our Services, if that difference is reasonably related to the value provided to us by your Personal Information.
5. Requests to Exercise Your Rights
Only you or a person 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 if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:
- Submitting a request to [email protected] or filling out this form
- Calling us toll-free at 833-846-8484
Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of your request and comply with your request in the time period required under the CCPA.
If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).
If you have implemented an opt-out preference signal (sometimes known as a global privacy control) through your browser or device, we will treat that opt-out preference signal as a valid request of your Right to Opt Out. Once we recognize the opt-out preference signal on our Services, we will automatically apply your Right to Opt Out to the browser or device through which we recognize the signal. The Services respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized). To learn more about opt-out preference signals, please visit https://globalprivacycontrol.org.
6. Data Sharing for Direct Marketing Purposes
California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at [email protected] or by writing us at the address found in the “Contact Us” section.
7. Changes to this Notice
Although most changes are likely to be minor, Tinuiti may change this Notice from time to time, and in Tinuiti’s sole discretion. We will indicate at the top of the page the modified notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current Notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.
8. Contact Us
Tinuiti welcomes any queries, comments, or requests you may have regarding this notice.
Tinuiti, Inc.
Attn: Marketing Department
121 S 13th Street, 3rd Floor
Philadelphia, PA 19107
Email: [email protected]
Phone: 833-846-8484