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AutoCruitment Privacy Notice Addendum for California Residents

Effective Date: 31st December 2019

This Privacy Notice Addendum for California Residents (the “California Addendum”) describes our collection and use of Personal Information and supplements the information contained in AutoCruitment’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this 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 notice.

Note that this California Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.

Where noted, this California Addendum also does not apply to personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). Unless otherwise noted, this exemption will expire on January 1, 2021.

INFORMATION WE COLLECT

Our https://trials.autocruitment.com and https://autocruitment.com websites (collectively, our “Website”) collects 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 or device (“personal information”). In particular, our Website collects, and has collected within the past twelve (12) months, the following categories of personal information from our consumers:

Category

Applicable Pieces of Personal Information Collected

  • A. Identifiers.
    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    A name, signature, physical characteristics or description, address, telephone number, education information, health insurance information, or medical information.
    Some personal information included in this category may overlap with other categories.
  • C. Protected classification characteristics under California or federal law.
    Age (40 years or older), race, country of residence, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familiar genetic information), or sexual orientation.
  • F. Internet or other similar network activity.
    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • G. Geolocation data.
    Physical location or movements.
  • K. Inferences drawn from other personal information.
    Profile reflecting a person’s psychological trends, predispositions, and behavior.

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) or clinical trial data;

USE OF PERSONAL INFORMATION

We may use, “sell” for monetary or other valuable consideration, or disclose, and we have used, “sold” for monetary or other valuable consideration, or disclosed within the past twelve (12) months, the personal information we collect for one or more of the following business or commercial purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to be contacted about, matched with, or otherwise to learn more about, a clinical trial, we will use that personal information to respond to your inquiry, such as for an applicable research clinic to contact you. (Categories A, B, C, F, G, K)
  • To provide, support, personalize, and develop our Website and services. (Categories A, F)
  • To create, maintain, customize, and secure your account with us. (Categories A, B, C)
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law). (Categories A, B, C, F, G, K)
  • For internal testing, research, analysis, and service development, including to develop and improve our Website, and to develop, improve, or demonstrate our services. (Categories A, B, C, F)
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, F, G, K)
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Categories A, B, C, F, G, K)
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AutoCruitment’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by AutoCruitment about our Website users is among the assets transferred. (Categories A, B, C, F, G, K)
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. (Categories A, B, F, G)
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider. (Categories A, B, C, F, G, K)
  • For clinical research purposes, including sharing such personal information with our third party clinical research partners and related third parties in connection with the foregoing (Categories A, B, C, K)

AutoCruitment 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.

Sales of Personal Information

As noted in our general Privacy Policy, we do not sell your personal information as the term “sell” is commonly understood to require an exchange for money. However, the California State Attorney General may issue guidance on whether the use of advertising and analytics cookies on our Website may be considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA to include both monetary and other valuable consideration. Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our Website and will comply with the restrictions of the “sale” of this information to the extent technologically feasible.

Personal Information Sales Opt-Out and Opt-In Rights

To exercise the right to opt-out, you (or your authorized representative) may adjust your cookie preferences by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website or other websites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu. You do not need to create an account with us to exercise your opt-out rights. You may be required to provide us with additional contact information so that we may verify your request to opt-in to the sale of your personal information. We will only use personal information provided in an opt-out request to review and comply with the request.

SOURCES OF PERSONAL INFORMATION

AutoCruitment obtains the categories, or subsets thereof, of personal information listed in the table above (in the “Information We Collect” section) from the following categories of sources:

  • Directly from you. For example, from forms you complete or services you obtain. (Categories A, B, C)
  • Indirectly from you. For example, from observing your actions on our Website. (Categories F, G, K)

SHARING PERSONAL INFORMATION

AutoCruitment may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we generally 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.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, AutoCruitment has disclosed the following categories of personal information for a business purpose to the listed categories of third parties:

  • A. Identifiers:
    Categories: Service Providers, Advertisers and advertising networks, Business partners, such as our clinical research partners, Social media companies, Internet cookie information recipients, such as analytics and behavioral advertising services
  • B. California Customer Records personal information categories:
    Categories: Service Providers, Advertisers and advertising networks, Business partners, such as our clinical research partners
  • C. Protected classification characteristics under California or federal law:
    Categories: Service Providers, Business partners, such as our clinical research partners
  • F. Internet or other similar network activity:
    Categories: Service Providers, Advertisers and advertising networks, Business partners, Social media companies, Internet cookie information recipients, such as analytics and behavioral advertising services
  • G. Geolocation data:
    Categories: Service Providers, Business partners, such as our clinical research partners
  • K. Inferences drawn from other personal information:
    Categories: Service Providers, Business partners, such as our clinical research partners

Sales of Personal Information

For purposes of this California Addendum, the term “sale” is used as defined under the CCPA, and generally excludes personal information which a consumer uses or directs us to intentionally disclose or where the consumer uses our business to intentionally interact with a third party, provided the third party does not also sell the personal information. In the preceding twelve (12) months, AutoCruitment has “sold” the following categories of personal information to the following categories of third parties for monetary or other valuable consideration:

  • A. Identifiers:
    Categories: Advertisers and advertising networks, and Internet cookie information recipients, such as analytics and behavioral advertising services
  • B. California Customer Records personal information categories:
    Categories: Advertisers and advertising networks, Social media companies, and Internet cookie information recipients, such as analytics and behavioral advertising services
  • F. Internet or other similar network activity:
    Categories: Advertisers and advertising networks, Social media companies, and Internet cookie information recipients, such as analytics and behavioral advertising services

We do not knowingly sell the personal data of minors under the age of 16 for monetary or other valuable consideration without affirmative authorization.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your authorized agent.

Authorized Agents

You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Access to Specific Information and Data Portability Rights

You have the right to request that AutoCruitment 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 or selling 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).
  • 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.

Deletion Request Rights

You have the right to request that AutoCruitment 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:

Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, see below. We may request additional information so we may confirm a request to delete your personal information.

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.

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

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will respond to a verifiable consumer request within ten (10) days of its receipt. We will process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 the verifiable consumer request’s receipt. 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 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.

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.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

OTHER CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g., requests made this year will receive information regarding such activities for last year). You may request this information once per calendar year. To make such a request, please send an email to info@autocruitment.com or write us at: AutoCruitment LLC, 101 6th Ave 8th Floor, New York, NY 10013.

CHANGES TO OUR PRIVACY NOTICE

AutoCruitment reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which AutoCruitment collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

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