Freedom Forever Privacy Notice for California Residents
Effective Date: 01/01/20
Last Reviewed on: 12/27/19
Background on the CCPA
Effective January 1, 2020, the CCPA allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.
Information We Collect About You
This 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”).
Information you provide to us and/or we receive from other sources
Within the last twelve (12) months, Freedom Forever may have collected and disclosed the following categories of Personal Information either directly from its consumers or from other sources:
|Category of Personal Information||How we use it||Legal basis for processing||CCPA categorization|
|Contact information and basic personal details. Such as your name, phone number, address, location, IP address, and e-mail address.||We use this information to communicate with you, including sending statements, news, alerts and marketing communications.|
We use this information to deal with inquiries and other requests made by you, including questions relating to our products and services.
|The processing is necessary for our legitimate interests, namely: for marketing purposes, and for communicating with you effectively and responding to your queries.|
The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, or when you interact with customer service, we will record your comments and opinions.||To provide, support, personalize, and develop this Website, products and services.|
To address your questions, issues, and concerns and resolve your inquiries, and monitor and improve our responses.
|The processing is necessary for our legitimate interests, namely: communicating with you effectively for the purposes of resolving your issues.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|Recruiting details. Contact information and basic personal details (as set out above); professional details and employment information such as resume, references, LinkedIn profile.||We use this information to facilitate recruiting.||The processing is necessary for our legitimate interests, namely: assessing your suitability for a role with Freedom Forever.||Identifiers.|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Professional or employment-related information.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
|The processing is necessary for our legitimate interest, namely: to administer and improve our services and business, and to develop new services.||Civ. Code § 1798.80(e)).|
Internet or other similar network activity.
Protected classification characteristics under California or federal law.
Information we automatically collect about you
Within the last twelve (12) months, Freedom Forever’s Website has automatically collected the following categories of Personal Information from its consumers:
|Categories of Personal Information||How we use it||Legal basis for the processing||CCPA categorization|
|Information about how you access and use this Website and customer portal. For example, the website from which you came and the website to which you are going when you leave this Website; your social media profiles; how frequently you access this Website; the time you access this Website and how long you use it for; whether you open emails or click the links contained in emails; whether you access this Website from multiple devices; and other actions you take. We also gather information, which may include Internet protocol (IP) addresses/ browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.||We use this information to: (a) conduct market analysis, monitor this Website and how it is used in order to improve our business and help us develop new products and services; and (b) generate marketing leads and determine news, alerts and other products |
and services that may be of interest to you.
|The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve our services and business.||Internet or other similar network activity.|
|Information about your device. We also collect information about the computer, tablet, smartphone or other electronic devices you use to connect to this Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers, and applications connected to this Website through the device, your Internet service provider or mobile network, your IP address.||We use this information to: (a) enable this Website to be presented to you on your device; and (b) |
operate, maintain and provide to you this Website’s features and functionality.
We use this information to monitor and improve this Website and business and to help us develop new products and services.
|The processing is necessary for the performance of a contract and (namely our Terms of Service).|
The processing is necessary for our legitimate interests, namely: to tailor this Website to the user and to improve our services generally.
|Internet or other similar network activity.|
Freedom Forever 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.
We may also use any information collected to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Personal Information does NOT include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- 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; and
- 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.
Sharing Your Personal Information
Freedom Forever 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 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. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Company has sold and/or disclosed your Personal Information for a business purpose to the following categories of third parties: (a) service providers and (b) data aggregators. Please refer to the table above for the categories of Personal Information the Company has sold and/or disclosed in the preceding twelve (12) months for a business purpose.
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.
1. Right to Request Access to Specific Information and Data Portability
You have the right to request that Freedom Forever 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 Your Rights and Choices), 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 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.
2. Right to Deletion Request
You have the right to request that Freedom Forever 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 Your Rights and Choices), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
3. Right to Opt-Out and Opt-In of Sale of Personal Information
If you are 18 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). Our website and services are not meant to be accessed or used by anyone under the age of 18. We do not knowingly sell or disclose the Personal Information of consumers we actually know are less than 18 years of age.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time.
You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.
To exercise the right to opt-out or opt back in, see Exercising Your Rights and Choices.
4. Right to Non-Discriminiation
We will not discriminate against you for exercising any of your CCPA rights outlined in this policy. This includes, but is not limited to, denying you goods or services, charging you different prices for similar services, or providing a different level or quality of service.
However, from time to time, 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.
Exercising Your Rights and Choices
To exercise the access, data portability, deletion, and opt-out/opt-in rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (877) 222-3940.
Only you, or your authorized representative, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a twelve (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 Personal Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.
Our Response Time and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the twelve (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.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at 43445 Business Park Dr. #110, Temecula, CA 92590.
Changes to Our Privacy Notice
Freedom Forever 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.
Phone: (877) 222-3940
Attn: Legal Department
43445 Business Park Dr. #110
Temecula, CA 92590