California Privacy Notice (CCPA)

Last Updated: 20th December 2023

Scope of Disclosures

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Acts (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available from government records, that is deidentified or aggregated such that it is not capable of being associated with you, or that is otherwise excluded from the CCPA’s scope.

These CA Disclosures also do not apply to information relating to our employees, contractors, applicants and other personnel. In addition, we often act as a “service provider,” as defined in the CCPA, processing personal information on behalf of our customers, and these CA Disclosures do not apply to the personal information processing we perform as a service provider.

Collection and Use of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the How We Collect and Use Personal Information section of our Privacy Notice.

In the last 12 months we have collected and disclosed for a business purpose the following categories of personal information:

  • Identifiers, such as full name, city, state, zip code, email address.
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name, mailing address, and log-in credentials.
  • Internet/Network Information, such as log data (including operating system and browser type) and clickstream data (including your usage and activity on our web sites and online services).
  • Inferences, such as predictions about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

We collect this information directly from you, from your browser or device when you interact with our services, from our clients or their agents, from information providers and from other publicly available sources. For more information about the personal information that we collect and how we collect it, please refer to the How We Collect and Use Personal Information section of our Privacy Notice.

We collect personal information from and about you for a variety of purposes. For example, we use personal information to communicate with customers about our services, to provide customers with our services, and to otherwise operate our business. For more information about our use of Personal Information, please refer to the How We Collect and Use Personal Information section of our Privacy Notice.

Disclosure of Personal Information

As described in the How We Share and Disclose Personal Information section of our Privacy Notice, we share personal information with Fraiser affiliates and with a variety of third parties for business purposes, or we may sell your personal information to third parties, subject to your right to opt out of those sales.

In the last 12 months, we have disclosed for a business purpose all categories of personal information outlined in the Collection and Use of Personal Information section above to our affiliates, our service providers, and our clients, which include political campaigns and non-profit entities.

In the previous 12 months, we have sold the following categories of personal information to third parties, subject to your Right to Opt Out: (i) Identifiers, and (ii) Commercial Information.

For more information about how we share personal information, please refer to the How We Share and Disclose Personal Information section of our Privacy Notice.

Sensitive Personal Information

In the last 12 months, we have collected the following categories of sensitive personal information:

  • Account log-in in combination with any required security or access code, password, or credentials allowing access to an account;

Fraiser only uses or discloses sensitive personal information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, for detecting security incidents, fraud and other illegal actions, to ensure the physical safety of natural persons, to perform services on behalf of the business (where the sensitive information is reasonably necessary and proportionate for this purpose), or for short term transient use. Fraiser only collects and processes sensitive information without the purpose of inferring characteristics about a consumer.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to confirm whether we are processing personal information about you, including:

  • The categories of personal information collected;
  • The categories of sources of the personal information;
  • The purposes for which the personal information were collected;
  • The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed;
  • The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and
  • The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold.

The Right to Access / Portability

You have the right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

The Right to Request Deletion

You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

The Right to Correction

You have the right to request that any inaccuracies in your personal data be corrected, taking into account the nature of the personal information and the purposes of the processing of the consumer’s personal information.

The Right to Opt Out of Sales or Sharing for Targeted Advertising

You have the right to direct us not to “sell” personal information we have collected about you to third parties for monetary or other valuable consideration, or their direct marketing purposes (now or in the future), or “share” your personal information to third parties for cross-context behavioral advertising purposes.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales or shares.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

How to Exercise Your California Privacy Rights

To Exercise Your Right to Access, Right to Know, Right to Deletion, or Right to Correction

Please submit a request by either:

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your Fraiser account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, address, order number, and/or date of last interaction with customer service.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

To Exercise Your Right to Opt Out of Personal Information Sales

Unless you have exercised your Right to Opt Out, we may “sell” personal information to third parties for monetary or other valuable consideration, or “share” your personal information to third parties for cross-context behavioral advertising purposes (targeted advertising). The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

To exercise your Right to Opt Out, please submit a request by clicking the following link: https://fraiser.org/data-request-form/

Do Not Sell or Share My Personal Information

You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Once you make an opt-out request, you may change your mind and opt back into future personal information sales at any time by contacting us at: privacy@fraiser.org.

Minors Under 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf by:

  • For requests to know, delete, or correct personal information:
  • Receiving a power of attorney valid under the laws of California from you or your authorized agent; or
  • Receiving sufficient evidence to show that you have:
  • Provided the authorized agent signed permission to act on your behalf;
  • Verified your own identity directly with us pursuant to the instructions set forth in these Disclosures; or
  • Directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
  • For requests to opt out of personal information sales: Receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@fraiser.org.