Disclosures for California Residents

Last updated: March 23, 2021

These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise those rights. The words used in this section have the meanings given to them in the CCPA, which may be broader than their common meaning. For example, the definition of “personal information” under the CCPA includes your name, but also more general information like age.

Notice of Collection.

The information we collect is described in greater detail above, under the headings Personal Data That We Collect and Non-Personal Or Aggregate Data That We Collect, the categories of personal information that we have collected—as described by the CCPA—including in the past 12 months are:

  • Identifiers—including name, email address, and IP address;
  • Other customer records—address, telephone number, loyalty card information, gift card information, and receipts;
  • Demographics—including your age;
  • Commercial information—including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • Internet activity—including browsing history, search history, information on your interactions with our Service;
  • Geolocation data—including location enabled services such as WiFi and GPS;
  • Sensory information—including audio, electronic, visual or similar information; and
  • Inferences—including information about your interest, preferences, and favorites.

We obtain the categories of personal information listed above directly from you. For example, when you create an account through the Service, you provide us with personal information like your name and email address. We also obtain the categories of personal information listed above indirectly from you from observing your actions on our Website. We may use or disclose the personal information we collect for the business purposes described above, under the heading Data Usage, including to provide and manage our Service.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

Right to Know and Delete.

California residents have the right to request we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.

To exercise your rights to know or delete described above, please submit a request by email us at privacy@tellumapp.com. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. We will require written proof of the agent’s permission to do so and verify your identity directly.

You may only submit a request to know twice within a 12-month period. If we are unable to verify your identity, we may deny your requests to know or delete. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, or email, and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will confirm receipt of your request within 10 business days. We endeavor to substantively respond to verifiable consumer request within forty-five (45) calendar days of receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

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 our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

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.

Right to Opt-Out.

We do not generally sell information as the term “sell” is traditionally understood. However, if and to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those implemented specifically for interest-based advertising, we will comply with applicable law as to such activity.

Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

Shine the Light.

If you are a California resident, you may ask for a notice describing what categories of personal information we share with third parties or affiliates for those third parties or affiliates’ direct marketing purposes and identify the name and address of the third parties that received such personal information. Please submit a written request to privacy@tellumapp.com and specify you want a copy of your California Shine the Light Notice. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.