This California Consumer Act Privacy Notice (“CCPA Notice”) applies to “Personal Information” (also referred to herein as “PI”) of “Consumers” collected by Splash as a “Business” (as these terms defined by the California Consumer Privacy Act (“CCPA”)). For avoidance of doubt, this CCPA Notice does not apply to information Splash collected about you as an event attendee. You should contact your event organizer for any questions you may have about the collection and processing of your PI by such event organizer.
We collect and share the following categories of PI from the corresponding sources and for the corresponding purposes set forth in the table below.
Performing services that you have requested from us
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity
Undertaking activities to verify or maintain or improve the quality or safety of our services
Undertaking internal research for technological development and demonstration
Short-term, transient use
Marketing
Performing services on behalf of us
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity
Undertaking activities to verify or maintain or improve the quality or safety of our services
Undertaking internal research for technological development and demonstration
Marketing
Performing services that you have requested from us
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain or improve the quality or safety of our services
Marketing
Performing services on behalf of us
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity
Undertaking activities to verify or maintain or improve the quality or safety of our services
Undertaking internal research for technological development and demonstration
Marketing
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 Privacy Policy.
We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a 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. Please refer to section 8 and 9 of our Privacy Policy for more information on your choices regarding certain kinds of online interest-based advertising.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so 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.
California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of 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. Please follow the instructions at our Data Rights Request page https://splashthat.com/privacy/data-rights-request and respond to any follow up inquires we may make. You may also obtain information on how to make, and may submit, a request by contacting us at privacy@splashthat.com.
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the 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. If we cannot comply 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.
To make a request according to your rights to know or to request deletion of your PI set forth below, please submit a request through https://splashthat.com/privacy/data-rights-request or by contacting us at privacy@splashthat.com. We will take steps to verify your identity before complying with the request to protect your privacy and security using your email address. We will send you an email to the email address that you provide to us, and you must take action on the email as described in the email. This will enable us to verify that the person who made the request controls and has access to the email address associated with the request. We will check our systems for the email address and any information associated with the email address. If you provide us with an email address that has not been used to interact with us in our provision of Services, then we will not be able to verify your identity. In other words, the only reasonable method by which we may verify the identity of individuals is if we have an email address on file that was provided to us in relation to our Services.
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:
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 in the period that is 12 months prior to the request date and are maintaining.
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.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
In addition to CCPA rights, certain Californians are entitled to the following notice:
Separate from your CCPA rights set forth above you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes: we may from time to time elect to share certain “personal information” (as defined by California’s “Shine the Light” law) about you with third parties for those third parties’ direct marketing purposes. California Civil Code § 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g. requests made in 2019 will receive information about 2018 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request by contacting us here https://splashthat.com/privacy/data-rights-request, or in writing at: One Clipboard, Inc. d/b/a Splash , 233 Broadway 28th Floor, New York, NY 10279 (Attention: Legal Counsel). Any such request must include “California 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.
