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California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) applies only to “personal information” about California residents, as that term is defined in the California Consumer Privacy Act, as may be amended, including by the California Privacy Rights Act (the “CCPA”), and it supplements the information in the rest of our Privacy Policy.

This section does not apply to personal information we collect in the following circumstances:

  • From employees or job applicants in their capacity as employees or job applicants; and
  • Information that we process as a service provider on behalf of other businesses, such as your employer or other companies with which you have a business relationship and which use the ISNetworld services or other solutions provided by ISN.

This Statement uses certain terms that have the meaning given to them in the CCPA and its implementing regulations.

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Biometric Information
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Geolocation Data
  • Employment Information: professional oremployment-related information
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our ISN Privacy Policy and for the following business purposes specified in the CCPA:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

2. Sources of Personal Information

We may obtain (and may have obtained during the 12-month period prior to the effective date of this Statement) personal information about you from the following categories of sources:

  • Directly from you
  • Your devices, such as when you download the Empower app
  • Our affiliates
  • Vendors who provide services on our behalf
  • Online advertising services and advertising networks
  • Data analytics providers
  • Government entities
  • Operating systems and platforms
  • Data brokers

3. Sale of Personal Information

We do not sell your personal information in exchange for monetary consideration.

4. Sharing of Personal Information

While we do not sell your personal information for monetary consideration, we may share it to support our own operational purposes in providing our Services (as defined in our Privacy Policy) to you. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, we may share personal information at your direction, such as when you choose to communicate with third parties through our Services.

5.       California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit a rights request, or to submit a request as an authorized agent on behalf of a customer, please email us at info@isn.com.  Where we are acting as a service provider to a business, if you wish to exercise any rights that may be available to you, you should direct your request to the business, who is the party responsible for responding to your requests.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may verify your identity by requiring you to sign in to your account.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.