The following are the categories of personal information we collect from consumers and the source of collection, in accordance with the categories of personal information enumerated in the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (we will refer to both as CCPA in this document). These are also the categories of information we collected in the past 12 months.
We retain the categories of personal information detailed below for a period of 90 days after the last date that we collected any of the consumer’s data. We delete the information after 90 days.
We do not use or disclose sensitive personal information.
Business Purposes of the Personal Information We Collect and Sell or Share
Sharing and Selling Your Personal Information
The chart below explains about the personal information we shared for online behavioral-targeted ads and sold to other parties in the preceding 12 months. Other than this sale and sharing, we have not disclosed your personal information for a business purpose in the preceding 12 months.
We do not have actual knowledge that we share the personal information of consumers under 16 years of age.
Right to Know
You have the right to know the following, which we will provide to you after we receive a verifiable request from you:
Right to Correction and Deletion
As permitted by regulation, 33Across will treat correction requests as a request to delete.
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is necessary to:
We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CCPA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Right to Designate an Authorized Agent to Submit CCPA Requests on Your Behalf
You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
If you would like to exercise any of your CCPA rights described above, please:
We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information to you, by using a two-points-of-data verification process.
Right to Opt-Out of the Sale or Sharing of Personal Information
We share and sell your personal information in certain instances, as explained above under “Sharing and selling your personal information”. You have a right to opt-out of that sharing and sale. If you would like to exercise your right to opt-out, please use the form available on our website at 33across.com/user-data-portal.
Last updated: [October 4, 2023]