CCPA

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

This CCPA Privacy Notice governs the manner in which FunpostOnline Ltd. (“Company”, "we" or “us” or “our”) processes information collected from consumers who reside in the State of California (“Consumers” as defined under the California Consumer Privacy Act of 2018 ("CCPA"), and will be referred herein as “you”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Further, this Privacy Notice is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:

  1. CATEGORIES of PERSONAL information WE COLLECT

We collect Personal Information which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below.
Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below.
Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
FunpostOnline have collected the following categories of personal information within the last twelve (12) months:

Category Example Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Yes: online identifiers, Internet protocol address, unique identifiers, real name, email address. 
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.		 No
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). No
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes: the user's interaction with our website.
G. Geolocation data. Physical location, approximate location derived from IP address or movements. Yes: approximate location.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history or performance evaluations. No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No
 
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No
 
L. Sensitive personal information. Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life. No

 

  1. categories of Sources of Personal Information
  • Directly and indirectly from activity on our website: For example, directly from you when you inquire about our Services via our website, or indirectly, we collect your usage data automatically from measurement tools.
  • Directly from you: For examplewhen contact us, etc.
  • Indirectly from you:  we track your activities across the internet, for example, when you view or interact with certain content, web page or ad.
  • From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.

 

  1. USE OF PERSONAL INFORMATION

We may use the Personal Information collected as identified above, for the following purposes: To fulfill or meet the reason you provided the Personal Information (support, respond to a query, etc.); monitor and improve our services; provide the services; marketing our services; analyzing our services and your use of the services and website; respond to law enforcement; or otherwise as detailed in our Privacy Policy.
We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
 

  1. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We may disclose your Personal Information to a contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information. 
In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:

# Category (corresponding with the table above) Category of Recipient Business Purpose
1 Category A
Category F
Category G
 		 Cloud computing and storage vendors. Storage, hosting.
2 Government Entities/ Law Enforcement Subject to a law request
3 operating systems Operating the services
4 Category A
Category F
Category G		 analysis providers Providing analytic data on the use of our website and services. We limit the providers ability to share such information, as detailed above.
5 Category A
Category F
Category G		 programmatic Measurement and reporting
6 Category A
Category F
Category G		 Marketing providers, CRM providers, social networks, advertising networks. marketing which is not cross-contextual, ad delivery.
7 Category A
Category F
Category G		 Service providers Improving the Services, development and optimization
       

 

  1. SALE OR SHARE OF PERSONAL INFORMATION

Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under CCPA to include a disclosure for cross-context behavioral advertising. FunpostOnline discloses the following categories of personal information for commercial purposes: identifiers, internet activity, non-precise geolocation data and inferences. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.
 
In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

Category (corresponding with the table above) Category Recipient Purpose of Sale or Share
Category A
Category F
Category G		 Ad-network Share for cross-context behavioral advertising.

 

  1. CHILDREN UNDER AGE 16

We do not knowingly collect information from children under the age of 16.
 

  1. DATA RETENTION

We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
The retention periods are determined according to the following criteria:

  1. For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
  2. To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
  3. To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
 
PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA and how to exercise them
The CCPA as replaced by the CPRA provides additional rights to California residents. This section addresses those rights and applies only to California residents.
 

  1. YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law.
 

California Privacy Right Details
The right to know what Personal Information the business has collected. The right to “access”. The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.
Deletion Rights. The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.
Correct Inaccurate Information The right to correct inaccurate Personal Information that a business maintains about a consumer
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.”
Opt-out from selling the right to opt-out of the sale or sharing of Personal Information by the business
Limit the Use or Disclosure of SPI Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.
Opt-Out of the Use of Automated Decision Making In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.
Non-Discrimination The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
Data Portability You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

 
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

  1. HOW CAN YOU EXERCISE THE RIGHTS?

As a third-party business, we do not have a direct interaction with the end-user, however we provide option to opt out of Sharing for Cross-Contextual Behavioural Advertising or Selling Personal Information by using the following opt-out options:

  • Use the “do not sell or share my information” footer on our website or click here.
  • Through Device-Level Choices:  if you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings. 
  • Opt-Out through Industry Consumer-Choice Platforms.  Finally, you can make choices about data collection for certain companies which participate in such tools, by visiting an industry consumer-choice platform, such as the NAI or DAA or EDAA.
  • by turning on a recognized opt-out preference signal, such as  the Global Privacy Control (“GPC”) signals.

Please know that opting out of interest-based advertising does not mean that you will not receive advertising.  You may still receive ads, but those ads may be less relevant to your interests.
The iinstructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer must provide are all detailed in the Data Subject Request, and send it to our privacy team:  [email protected].
 

  1. AUTHORIZED AGENTS

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
 

  1. NOTICE OF FINANCIAL INCENTIVE

We do not offer financial incentives to consumers for providing Personal Information.
 
CONTACT US:
FunpostOnline Ltd.

 
UPDATES:
This notice was last updated on December 22, 2022, as required under the CCPA, we will update the CCPA Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this CCPA Notice.
 
PART III: OTHER CALIFORNIA OBLIGATIONS
Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form available here.
 
Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites.
For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
 
 
 
ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS: Nevada law requires certain businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer from whom FunpostOnline has collected personal information and you wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected]. You may also submit a request to opt-out by clicking Do Not Sell My Personal Information from the footer of the website or submitting a DSR.