California Privacy Notice
Effective Date: July 2021
Section 1 of this Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the preceding twelve months. Sections 2 and 3 explain how California residents may exercise their California privacy rights. This Notice does not apply to information that is exempt from certain requirements of the applicable California privacy laws, including information collected from job applicants, contractors, and current and former employees, and information concerning certain business-to-business communications and transactions between us and individuals acting in representative capacities on behalf of companies and other organizations. Therefore, if we collect information about you in either of those contexts, this Notice will not be applicable to you.
Our practices in calendar year 2021 may change and if we make material changes we will provide notice about the new collection or use.
1. Collection, Use and Disclosure of Personal Information
Generally, we collect, retain, use, and share your PI to provide you the CEI Sites, which may include but is not limited to https://www.coxenterprises.com, https://www.coxconservesheroes.com, and https://www.ajc.com as otherwise related to the operation of our business. In addition, we may collect, use, and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this Notice.
Information We Collect
During the preceding 12 months, we may have collected the following categories of personal information about you:
- Identifiers: such as name, nicknames, aliases, contact information including email, phone, and address, User IDs, passwords, IP addresses, device IDs, and account names and numbers;
- Personal Records: such as financial account information you have shared with us;
- Personal Characteristics and Traits: such as age, gender, and household information;
- Customer Account Details / Commercial Information: such as purchase or service history;
- Internet Usage Information: such as browsing history, referring URLs, search history, interactions with advertising links, and mobile application usage;
- Geolocation Data: such as your location we infer based on your IP address;
- Sensory Data: such as voice recordings from call centers or profile photos you place on your profile;
- Inferences from PI Collected: such as customer profiles including subscriber preferences, customer characteristics, and behaviors.
Our Business Purposes
- Providing the CEI Sites and our products and services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services;
- Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
- Debugging the CEI Sites to identify and repair errors;
- Internal research and development;
- Quality and safety assurance, and improving, upgrading, and enhancing the CEI Sites and our products and services;
- Processing and managing interactions and transactions on the CEI Sites and our products and services;
The following categories of PI are shared with the following categories of third parties for Business Purposes only:
- Our Affiliates: identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI;
- Vendors: identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI;
- Analytics and Advertising Partners: personal characteristics and traits, internet usage information, geolocation data, and inferences from PI;
- Our Joint Marketing Partners: personal characteristics and traits, internet usage information, geolocation data, and inferences from PI;
- Business Partners: identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI;
- Social Media Platforms: personal characteristics and traits, internet usage information, geolocation data, and inferences from PI;
- Government Entities, Including Law Enforcement: upon request and as required under law, we may provide identifiers, personal records, personal characteristics and traits, customer account details and commercial information, internet usage information, geolocation data, sensory data, and inferences from PI.
2. Your CCPA Rights
Right to Opt-Out of Sale of Personal Information
We do not knowingly sell your PI. For this reason, we do not treat PI collected by CEI as subject to a Do Not Sell request and, therefore, we do not offer a way for you to submit such a request. There is not yet an industry consensus as to whether third-party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA and as such, we do not treat such information as subject to a Do Not Sell request.
However, third parties may collect personal information through our online services for advertising, analytics, and other purposes. Please visit here to opt-out of what these participating third parties consider a sale of personal information by such parties. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit here or here.
You can exercise control over browser-based cookies by adjusting the settings on your browser. For additional details about your choices regarding certain kinds of online interest-based advertising, visit here.
Some browsers have signals that may be characterized as do-not-track signals, but as this is not an actual request from a person, we currently do not recognize these as a Do Not Sell request. We understand that various parties are developing do-not-sell signals, and we may recognize certain such signals if we conclude such a program is appropriate. Note that we do not recognize do-not-track signals on a general basis either.
We may disclose your PI for the following purposes, which are not a sale: (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures among the entities that constitute CEI, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.
We do not knowingly sell the PI of Consumers we know are under 16. Any California residents under the age of 18 who have registered to use the CEI Sites, and who posted content or information on the CEI Sites, can request removal by contacting us at firstname.lastname@example.org detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
Rights to Know and Delete Personal Information
California Consumers have the right to exercise certain privacy rights under the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know or delete. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above.
Some personal information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. Under the CCPA they are exceptions to your request rights. If we do not comply fully with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
You may use an authorized agent to submit a consumer rights request. If you use an authorized agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent.
a. The Right to Know
i. Categories of PI
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you;
- The categories of sources from which we collected your PI;
- The business or commercial purposes for our collecting or selling your PI;
- The categories of third parties to whom we have shared your PI;
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred;
- A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain the categories of your PI we have sold and the categories of third parties to which we sold PI, by categories of PI sold for each third party.
ii. Specific Pieces of PI
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected, and are maintaining, in the period that is 12 months prior to the request date. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
b. The Right to Deletion
You may request that we delete your PI that we have collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your personal information as permitted by applicable law, such as for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your PI that we did not collect directly from you.
To exercise the right to know or right to delete, you may submit a request by emailing us at email@example.com and including your name, address, email address, and phone number. Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquires we may make, and we may deny your request if you do not do so. CEI will not discriminate against any consumer for exercising these rights, as described further below.
Notice of Financial Incentive and Non-Discrimination
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale, and retention and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive, if offered, will be explained and described in its program terms, as applicable. Please note that participating in incentive programs is entirely optional. You will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and applicable terms so check them regularly.
Notwithstanding anything to the contrary, we may collect, use, and disclose your PI as required or permitted by applicable law and this may override your CCPA rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
3. California Shine the Light Law
Separate from your CCPA rights, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes without your consent. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at firstname.lastname@example.org or by sending a letter to:
Cox Enterprises Inc.
ATTN: Chief Privacy Officer: Shine the Light Request
6205-A Peachtree Dunwoody Road
Atlanta, GA 30328
Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.
As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
4. Contact CEI.
If you have any questions about this Notice, please contact CEI at email@example.com.
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