California Consumer Privacy Act (CCPA) Addendum

This Kwanzoo California Consumer Privacy Act Addendum (this “CCPA Addendum”) supplements the Kwanzoo Privacy Policy dated 19th April 2018. This CCPA Addendum addresses Kwanzoo’s responsibilities to our clients and required disclosures to California consumers under the California Consumer Privacy Act of 2018, or CCPA. This CCPA Addendum supplements the Kwanzoo Privacy Notice (“Privacy Notice”).

In this CCPA Addendum, we use the following terms:

• “client” refers to a business which uses Kwanzoo’s services on Kwanzoo.com and serves ads through ads.kwanzoo.com;
• “business,” “business purpose,” “consumer,” “commercial purpose,” “personal information,” “sale” or “selling,” and “service provider” refer to the definitions in the CCPA;
• “Kwanzoo Service” refers to the Kwanzoo SaaS platform on Kwanzoo.com and the provision of associated professional services that we provide to our clients;
• “user” refers to an individual who views or clicks through online display ads served through ads.kwanzoo.com on behalf of the client, and then performs further actions on the client’s website; and
• “respondent” refers to an individual who is prompted to provide a response to one of Kwanzoo’s clients through the Kwanzoo Service.

Kwanzoo’s activity related to the CCPA

For the purposes of this notice, Kwanzoo has two areas of activity that are related to the CCPA.

First, Kwanzoo collects data from users in the course of providing the Kwanzoo Service to its clients. In this activity, Kwanzoo acts strictly as a “service provider” to our clients under the CCPA, and our clients are “businesses”.

In the Kwanzoo Service, Kwanzoo collects respondent data strictly based on our clients’ instructions (e.g. from a conversational chat session on the client’s website). For example, our clients specify what respondent data we should collect, how we should provide that data back to the client. Kwanzoo’s clients also decide how to use or respond to any data that is collected.

Second, Kwanzoo collects data from users in the course of our own marketing efforts. This includes information we collect voluntarily from forms on our website and event registrations, information we collect automatically when users visit our website, and information we obtain from third party sources. In this activity, Kwanzoo acts as a “business” under the CCPA.

Kwanzoo’s handling of personal information under the CCPA

Regardless of which area of activity applies to you, Kwanzoo does not sell your personal information.

To be clear, in the previous 12 months we have not sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated a consumer’s personal information to another business or third party for monetary or other valuable consideration. If that changes, we will update this notice.

Further, when we provide the Kwanzoo Service to our clients, we do not:

• process personal information for any commercial purpose other than providing our clients the products and services they have purchased; or
• retain, use or disclose personal information outside of the scope of the agreements we have with our clients.

Kwanzoo’s handling of personal information under the CCPA

Regardless of which area of activity applies to you, Kwanzoo does not sell your personal information.

To be clear, in the previous 12 months we have not sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated a consumer’s personal information to another business or third party for monetary or other valuable consideration. If that changes, we will update this notice.

Further, when we provide the Kwanzoo Service to our clients, we do not:

• process personal information for any commercial purpose other than providing our clients the products and services they have purchased; or
• retain, use or disclose personal information outside of the scope of the agreements we have with our clients.

Personal information collected and disclosures for business purposes

The CCPA requires that we disclose the categories of personal information we collect about consumers, and the categories of personal information we disclose for a business purpose.

The chart below details where you find information about the categories of personal information that Kwanzoo has collected in the previous 12 months for each activity related to the CCPA.

ActivityWhere you can find informationProviding the Kwanzoo Service to Kwanzoo clients as a “service provider”.The categories of personal information Kwanzoo collects about users vary depending on our clients’ implementation and use of our software.

For more information on the types of data collected by a particular Kwanzoo client, refer to the Privacy Notice or the communications of the Kwanzoo client.

Our clients’ privacy notices are commonly located on the client’s web site.

Carrying out Kwanzoo’s marketing efforts as a “business”.See the section of our Privacy Notice titled “With Whom We Share Information” and “Your Choice in Information Use”.

The chart below details where you can find information about the categories of information we disclose for a business purpose in the previous 12 months.

ActivityWhere you can find informationProviding the Kwanzoo Service to Kwanzoo clients as a “service provider”.The categories of personal information Kwanzoo discloses for a business purpose vary depending on the features of our software our clients use, and the servicing and support they have purchased.

For more information on the types of data collected by a particular Kwanzoo client, refer to the Privacy Notice or the communications of the Kwanzoo client.

Our clients’ privacy notices are commonly located on the client’s web site.

Carrying out Kwanzoo’s marketing efforts as a “business”.See the section of our Privacy Notice titled “With Whom We Share Information” and “Your Choice in Information Use”. 

Consumer rights under the CCPA

Your rights under the CCPA include the right to request a copy of the specific personal information collected about you in the 12 months prior to the request, and a business’s data collection practices (including categories of information collected, how the information is used, and who it is disclosed to). We will generally refer to these as “access requests”.

In addition, with some exceptions, you can request deletion of the personal information that is collected about you. We will generally refer to these as “deletion requests”.

With respect to personal data of consumers collected in the Kwanzoo Service, Kwanzoo’s clients are responsible for fulfilling access and deletion requests. Kwanzoo supports these requests by offering our clients product features, processes and assistance in exporting personal information about individuals. These product features and processes complete the data deletion within 30 days of receiving the request from our client.

With respect to the personal data of consumers collected in Kwanzoo’s marketing efforts, we are responsible for fulfilling access and deletion requests

.

Activity

How to exercise your access and deletion rightsProviding the Kwanzoo Service to Kwanzoo clients as a “service provider”.Please contact the Kwanzoo client identified in the communication you received.

Contact information is commonly located within the communication or in a privacy policy linked from the communication.

Carrying out Kwanzoo’s marketing efforts as a “business”.Please submit a request to privacy@Kwanzoo.com.

In the request, please be as specific as possible in relation to the personal information you wish to access or delete. Once we receive the request, we will review it, and process the request accordingly. If we need additional information to verify your identity, we will let you know.

Any identifying information in such requests will be used solely for verification, and to communicate with you. We will respond to the request within 45 days of receipt, or notify you if you require additional time.