Updated August 4, 2020
NOTICE AT COLLECTION
Our Collection and Use of Your Personally Identifiable Information
As part of the normal operation of the Website, we may collect and, in some cases, use or disclose personally identifiable information (referred to herein as “personally identifiable information” or “PII”) about you where we reasonably believe it will help us administer our business or provide products, services or other opportunities to you as described below.
For your convenience, we are listing the categories of PII that we collect below and have collected within the past 12 months:
|Category||What We May Collect||How Collected||Reason for Collection*|
|Identifiers.||A real name, email address, phone number, company name, company domain, contact location, title, LinkedIn ID, website interaction, IP address.||Through the website, through our software platform, written correspondence, e-mail and/or by telephone.
|To provide and/or market a service or product to you or complete a transaction for you; marketing and promotional efforts.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
|A name, address, telephone number.
|Through the website, through our software platform, written correspondence, e-mail and/or by telephone.
|To provide and/or market a service or product to you or complete a transaction for you; marketing and promotional efforts.|
|Internet or other similar network activity.
|Browsing history, information on a consumer’s interaction with our website, analytics.||Through the website, through our software platform.||To provide and/or market a service or product to you or complete a transaction for you; marketing and promotional efforts.|
|Inferences drawn from other personal information.
|Insight from frequency of viewers.||Through the website, through our software platform.|
*In addition to the reasons for collection described above, we may, in our sole discretion, retain original and updated PII as part of our records for reasons such as technical constraints, legal requirements, dispute resolution, trouble-shooting and agreement enforcement.
In addition to PII, we may also collect, aggregate, and share “Non-PII” which is information that is aggregated, anonymized, de-identified and is unable to be readily identified to you.
CREDE collects information from our users at several different points, including but not limited to the following:
Personally Identifiable Information You Provide To Us
Any personal information that we may collect about you is voluntarily provided to us by you. We receive and may store the information you provide to us. As you navigate through the Website, there are several online forms which you can use to request information about us. In order for us to respond to your request, we ask that you provide to us, among other things, your first and last name, mailing address, telephone number, and email address on the online form. Other information may be identified as optional, and you may choose whether or not to provide it. The use of these online forms is completely voluntary. We may use your first and last name, email address, mailing address and telephone number to contact you from time to time. In addition, we may use that information internally for assessing our business and how the Website is used. Visitors to the Website may navigate the entire Website without using any of these features or providing any information.
If you correspond with us, we may retain such information and PII included as part of the correspondence. In addition, where we have sent an email to you, we may receive confirmation that you have opened it. If you want to unsubscribe from a CREDE’s email list, please let us know by following the “Unsubscribe” instructions that are included in each promotional email from us. Please note that such requests may take up to ten (10) days to become effective.
Cookies and Other Tracking Methods
Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. To view more information regarding cookie settings please visit:
For Microsoft Internet Explorer:
For Microsoft Edge:
For Google Chrome:
For Mozilla Firefox:
(b) “Remarketing with Google Analytics” to place ads on other sites directed to people who have visited the Website.
(c) “Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Website.
You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing the ad settings at https://support.google.com/ads/answer/2662856. You also can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at https://tools.google.com/dlpage/gaoptout/.
Target Driven Marketing
We use a software platform called Target Driven Marketing that collects PII, as well as cryptic hash codes for all visitors which can be used to remarket to them via other social media platforms like Instagram, Facebook, LinkedIn and others.
Personally Identifiable Information and Information from Other Sources
We may receive PII and information about you from other sources, such as our agents, vendors, and service providers and from publicly available sources. For example, sometimes we receive updated address information from third parties that we may use to update our records.
Disclosing Personally Identifiable Information To Third Parties
We do not sell, share, disclose or rent your personally identifiable information with any third parties. All PII is utilized for internal purposes only.
Sale of Personally Identifiable Information
In the preceding twelve (12) months, we have not sold personally identifiable information.
Inapplicability of Privacy Policies of Any Linked Websites or Other Third Parties
Our Website contains links to or integrations with other sites, whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.
Protection of Personally Identifiable Information
We have put in place appropriate physical, electronic and managerial procedures to safeguard against foreseeable risks, such as unauthorized access. Please be aware that the Website and data storage are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. We are not responsible for the acts and omissions of any third parties.
No transmission of data over the internet is guaranteed to be completely secure. We cannot guarantee the security of the information on and sent from the Website. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect your personally identifiable information, we cannot ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.
Compromise of Personally Identifiable Information
In the event that PII is compromised as a result of a breach of security, we will promptly notify those persons whose PII has been compromised, in accordance with applicable law.
Information from Children
Notice of Privacy Rights of California Residents
Personal Information Shared for Direct Marketing Purposes
If you are a California resident and have provided personal information to us, you are entitled by law to request certain information about the personal information we shared, if any, with other businesses for their own direct marketing uses. To make such a request, send an email email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. Include the website or line of business to which your request pertains. We will provide the requested information to you at your e-mail address in response. Please allow thirty (30) days for a response. We are required to respond to only one request per customer each year, and we are not required to respond to requests made by means other than through the above email address.
We will not share your personal information with third parties for their direct marketing purposes if you request that we do not do so. You may make such a request by sending us an email at firstname.lastname@example.org or mailing your request to CREDE, 18301 Von Karman Avenue, Suite 510, Irvine, California 92612, Attention: Privacy Officer. When contacting us, please indicate your name, address, email address, which website or line of business to which your request pertains, and what personal information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request.
California Do Not Track Disclosures
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (DNT) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks, and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, please visit: www.allaboutdnt.org.
Privacy Notice for California Residents
The following sections apply to California residents, only.
California Residents: Your Request Rights
1) If you are a California resident, you may request that we disclose the following:
(a) The categories of personal information we have collected about you.
(b) The categories of sources from which the personal information is collected.
(c) The business or commercial purpose for collecting or selling personal information.
(d) The categories of third parties with whom we share personal information.
(e) The specific pieces of personal information we have collected about you (also called a data portability request).
We do not knowingly collect, sell, share, or disclose personal information from children under 18.
2) If you are a California resident, we are obligated to make additional disclosures if we choose to sell or share your data for business purposes. While we do not sell your personal information, we may disclose your personal information to third parties in the ordinary course of business. Following this, we will disclose the following at your request:
(a) The categories of personal information that the business collected about you.
(b) The categories of personal information that the business sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
(c) The categories of personal information that we have disclosed about you for a business purpose.
You may request the above information at least twice per 12-month period. We will ask for some verification to comply with this request in order to protect your privacy.
3) If you are a California resident, you may also make a request to delete the information we have collected about you.
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
Access to Specific Information and Data Portability Rights
You have the right to request that we 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, 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:
(1) Sales, identifying the personal information categories that each category of recipient purchased; and
(2) Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not knowingly collect, sell, share, or disclose personal information from children under 18 years of age.
Deletion Request Rights
You have the right to request that we 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, 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.
Right to Opt-Out
If CREDE sold your personal information, you would have the right to direct us to not sell your personal information at any time (the “right to opt-out”). However, CREDE does not sell personal information in the last twelve (12) months and has no plans to sell personal information in the next twelve (12) months.
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 filling out the form HERE or by contacting us at email@example.com or calling us at 1 (855) 805-7400 describing your request(s). The verification we may request will reflect personal information that you have previously provided to us.
Only you, or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. These requests are free, though we reserve the right to implement a reasonable fee for excessive or complex requests you may submit. 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.
Before responding to a request by you, we will ask you to verify your identity using personal information you have previously provided to us, in order to protect your privacy. The manner in which we do so will vary on how you make a request and what is being requested. For example, if you submit an inquiry via email, we will respond with an email requesting verification. Otherwise, we may ask you verbally if you make this request over the phone (or in person). We may not be able to oblige all requests, as we are prohibited from disclosing some information.
In the event that you are using an authorized agent to request a disclosure or the deletion of your information, please send us a signed letter, including your name, email, your agent’s name, and your agent’s email, authorizing your agent. We may then ask you to verify your identity with us by email before responding to a request by your agent. Alternatively, you may directly confirm with us that the agent is authorized to submit the request.
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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request for access to information or deletion within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We endeavor to respond to a verifiable request to opt-out within fifteen (15) days of its receipt.
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 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.