California Privacy Notice

Last Updated: February 17, 2020

This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of Crucial Data Solutions, Inc. (“CDS,” “we,” or “us”), which is incorporated in this privacy notice by this reference.  This privacy notice applies to California residents from whom we collect personal information (“consumers” or “you”), including when you use the Service (as defined in our general Privacy Policy.  We adopt this privacy notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this privacy notice.

As noted in our general Privacy Policy, CDS processes Client Data on behalf of its Clients. This information is under the direct control of the Client. If you believe that the Client Data of a Client may include your personal information and have any questions about its use, please contact that Client and review that Client’s privacy policies.

Information We Collect

The Service collects 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 or household (“personal information”). In particular, within the last 12 months, CDS has collected the following categories of personal information from the sources and for the business or commercial purposes described below:

Description of Category
What We Collect
Identifiers (“Identity Data”).
A real name, alias, internet protocol address, email address
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”).
A name
Biometric information (“Biometric Data”).
Biological or behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints and faceprints.
Internet or other similar network activity (“Internet Use Data”).
Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data (“Location Data”).
Physical location or movements.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

The purposes for our collection of personal information is set forth in our general Privacy Policy.

Disclosures of Personal Information for a Business Purpose

We do not share your personal information for a business purpose to third parties. 

In the preceding 12 months, we have not disclosed personal information to any third parties for a business purpose.

Your Rights and Choices

The CCPA provides you as California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

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 (see Exercising Access, Data Portability, and Deletion Rights), 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 that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • Regarding any disclosures for a business purpose, the personal information categories that each category of recipient obtained.

Deletion Rights

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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 either of the following methods:

Only you, or someone legally authorized 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:

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

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, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the receipt of a 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 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 the request is excessive 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. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.

Non-Discrimination

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

  • Deny you goods or services
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
  • Provide you a different level or quality of goods or services, including denial of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

We will not share any personal information with third parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.

Changes to this Privacy Notice

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this privacy notice, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised privacy notice has become effective indicates that you have read, understood, and agreed to the current version of the privacy notice.

Contact Us

If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us at:

Site: https://www.crucialdatasolutions.com/
Email: dpo@crucialdatasolutions.com

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