CCPA Privacy Notice

Effective Date: July 2020

1 | CCPA INTRODUCTION AND OVERVIEW
Vision Media Management & Fulfillment LLC (“Company,” “we,” “our,” or “us”) takes your privacy seriously. We want you to know how we collect, use, share, and protect your Personal Information and about the rights of California Consumers under California law.

This Privacy Policy addresses the following topics

The Scope of this Privacy Policy
The Company’s Collection, Use and Disclosure of Personal Information
Your California Privacy Rights
How to Exercise Your Rights
Additional Rights Under California Law
Changes to This California Privacy Policy
For More Information

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at 800-805-0795 or privacy@visionmedia.com for assistance.

2 | THE SCOPE OF THIS PRIVACY POLICY

What Is Personal Information?

“Personal Information”. “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

Whose Personal Information Is Covered By This Policy?

This California Privacy Policy applies to the Personal Information of residents of the State of California in their capacity as consumers (“California Consumers”).

What Personal Information Does This Privacy Policy Cover?

This Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers’ (a) visits to our website; (b) emails; and (d) use of our products and services that references this Privacy Policy (collectively, the “Services”).

Whose Personal Information Is Not Covered By This Privacy Policy?

For purposes of this Privacy Policy, “Consumer” does not include:

Individuals who are NOT California residents.
California residents who are Company’s employees, job applicants, or contract workers (collectively, “HR Individuals”), or the emergency contacts of HR Individuals or the dependents or spouses who receive Company benefits by virtue of their relationship to an HR Individual in their capacities as HR Individuals or emergency contacts, dependents, or spouses; or
California residents who are employees or other agents of a business engaged in a transaction with Company in their capacities as employees or agents of that business.

3 | THE COMPANY’S COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION
This section of the Privacy Policy describes, for the 12 months preceding the date last updated, above, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information. Unless we inform you otherwise, this section also serves as our “Notice at Collection” by informing you of your Personal Information to be collected in the future and the purposes for its use.

Categories Of Personal Information Collected

Identifiers, including: real name, postal address, telephone number, unique personal identifier, online identifier and related logon credentials, internet protocol address, signature, and email address.
Characteristics of protected classifications under California or federal law, including: date of birth.
Commercial information, including: products and services usage information, session information, usage length, type of service purchased.
Internet or other electronic network activity information, including: device information, browsing history including the IP address of last site visited, and time and date of log-in.
Geolocation information, including: geographic location, postal code, time zone or website user and device.
Professional or Employment-Related Information, name of employers, job title, department.
Inference information, including: consumer preferences, third-party affiliations for discount program participation.

Sources Of Personal Information and Purposes For Using Personal Information

In the last 12 months, Company collected the categories of Personal Information listed above from the following sources: (1) Directly from California resident customers; and (2) Website Users, and used those categories of Personal Information for the following purposes:

Categories of Personal Information Collected in the Last 12 Months	Sources of that Personal Information	Business Purposes and Commercial Purposes for Collecting that Personal Information
Identifiers (1) Collected from Customers: Real name, postal address, telephone number, unique personal identifier, online identifier and related logon credentials, internet protocol address, signature, and email address (2) Collected from Website Users: Real name, email address, phone number	(1) Source of Collection: Directly from Customers (2) Source of Collection: Users	(1) For Customers: Content Services, including order fulfillment, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Short-term, transient use. Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback. (2) For Website Users Respond to sales requests. 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, and providing analytic services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Short-term, transient use.
Characteristics of protected classifications under California or federal law Collected from Customers Date of birth	Source of Collection Directly from Customers	For Customers Accessing content
Commercial information Collected from Customers Product and service usage, session information, length and date of usage		For Customers Accessing content Performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Short-term, transient use. Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.
Internet or other electronic network activity information (1) Collected from Customers Device information, browsing history including the IP address of last site visited, and time and date of log-in (2) Collected from Website Users Aggregated data pertaining to website usage	(1) Source of Collection Directly from Customers (2) Source of Collection Automated technologies in the website, such as Google Analytics	(1) For Customers Accessing content Performing services, including order fulfillment, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services. (2) For Website Users For marketing and for general improvement in services provided
Geolocation data Collected from Website Users Latitude and longitude location information, postal code, time zone of website user and device.	Source of Collection Website users	For Website Users Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services.
Professional or employment-related information Collected from Customers Name of employer, job title, job description, department, affiliation	Source of Collection Directly from Customers	For Customers Verifying customer information, providing advertising or marketing services. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.
Inference information Collected from Customers Consumer preferences, third-party affiliations for discount program participation	Source of Collection Directly from Customers	For Customers Performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services.

Categories of Personal Information Collected in the Last 12 Months

Sources of that Personal Information

Business Purposes and Commercial Purposes for Collecting that Personal
Information

Identifiers

(1) Collected from Customers:

Real name, postal address, telephone number, unique personal identifier, online identifier and related logon credentials, internet protocol address, signature, and email address

(2) Collected from Website Users:

Real name, email address, phone number

(1) Source of Collection:

Directly from Customers

(2) Source of Collection:

Users

(1) For Customers:

Content

Services, including order fulfillment, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Short-term, transient use.

Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services.

Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys.

Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.

(2) For Website Users

Respond to sales requests.

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, and providing analytic services.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Short-term, transient use.

Characteristics of protected classifications under California or federal law

Collected from Customers

Date of birth

Source of Collection

Directly from Customers

For Customers

Accessing content

Commercial information

Collected from Customers

Product and service usage, session information, length and date of usage

For Customers

Accessing content

Performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Short-term, transient use.

Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services.

Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys.

Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.

Internet or other electronic network activity information

(1) Collected from Customers

Device information, browsing history including the IP address of last site visited, and time and date of log-in

(2) Collected from Website Users

Aggregated data pertaining to website usage

(1) Source of Collection

Directly from Customers

(2) Source of Collection

Automated technologies in the website, such as Google Analytics

(1) For Customers

Accessing content

Performing services, including order fulfillment, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services.

(2) For Website Users

For marketing and for general improvement in services provided

Geolocation data

Collected from Website Users

Latitude and longitude location information, postal code, time zone of website user and device.

Source of Collection

Website users

For Website Users

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Undertaking activities to verify or maintain the quality of products and services provided to customers, and to improve, upgrade, or enhance products and services.

Professional or employment-related information

Collected from Customers

Name of employer, job title, job description, department, affiliation

Source of Collection

Directly from Customers

For Customers

Verifying customer information, providing advertising or marketing services.

Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.

Inference information

Collected from Customers

Consumer preferences, third-party affiliations for discount program participation

Source of Collection

Directly from Customers

For Customers

Performing services, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services.

Disclosure Of Personal Information To Third Parties

In the last 12 months, Company disclosed the following categories of Personal Information about California Consumers to the following categories of third parties for a business or commercial purpose:

Category of Personal Information	Categories of Third Parties with Whom We Disclose Categories of Personal Information for a Business Purpose in the Last 12 Months
Identifiers (1) Collected from Customers: Real name, postal address, telephone number, unique personal identifier, online identifier and related logon credentials, internet protocol address, signature, and email address (2) Collected from Website Users: Real name, email address	For Customers A third-party online media and video platform. A SaaS provider of customer care services. A SaaS provider of email delivery services. An international provider of shipping and delivery products and services. A leading provider of shipping and supply chain management services. A leading provider of cloud computing services. A cloud-based marketing, sales, and customer services platform. A regional provider of IT support and services. A specialty business process software development company. (2) For Website Users A third-party online media and video platform. A SaaS provider of customer care services. A SaaS provider of email delivery services. A leading provider of cloud computing services. cloud-based marketing, sales, and customer services platform. A regional provider of IT support and services.
Characteristics of protected classifications under California or federal law Collected from Customers Date of birth	A leading provider of cloud computing services.
Commercial information Collected from Customers Product and service usage, session information, length and date of usage	A leading provider of cloud computing services.
Internet or other electronic network activity information (1) Collected from Customers Device information, browsing history including the IP address of last site visited, and time and date of log-in. (2) Collected from Website Users Aggregated data pertaining to website usage	A third-party online media and video platform. A SaaS provider of customer care services. A leading provider of cloud computing services.
Geolocation data Collected from Website Users Latitude and longitude location information, postal code, time zone of website user and device.	A third-party online media and video platform. A SaaS provider of customer care services. A leading provider of cloud computing services.
Professional or employment-related information Collected from Customers Name of employer, job title, job description, department, affiliation.	A third-party online media and video platform. A SaaS provider of customer care services. A leading provider of cloud computing services.
Inference information Collected from Customers Consumer preferences, third-party affiliations for discount program participation	A SaaS provider of customer care services. A SaaS provider of email delivery services. A leading provider of cloud computing services. A cloud-based marketing, sales, and customer services platform.

No Sale Of Personal Information

Vision Media does not and will not sell California Consumers’ Personal Information.

4 | YOUR CALIFORNIA PRIVACY RIGHTS

1. Right to Know

California Consumers have the right to submit a verifiable request to know:

The categories and specific pieces of Personal Information that Company has collected about them;
The categories of sources from which Company collected the Personal Information;
The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
The business or commercial purposes for Company’s collection, disclosure, or sale of the Personal Information.

2. Right To Delete

California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Company has collected from the Consumer.

3. Right to Opt Out of Sale of Personal Information

California Consumers have a right to opt-out of the sale of the Personal Information. However, as stated above, Company does not and will not sell Personal Information.

5 | HOW WE PROTECT PERSONAL INFORMATION.

1. Making Requests

Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:

Complete the online request form available here: https://www.visionmediaprivacy.com/privacy-request/

Contact by telephone: 800-805-0795

2. Requests By Authorized Agents

You can have an authorized agent submit a CCPA request to us on your behalf by (a) providing us with a written authorization signed by you that designates the agent as your authorized agent for purposes of a CCPA request; (b) verifying your identity directly with us; and (c) directly confirming with us that the agent is authorized to submit the request.

3. How We Will Verify Your Requests

To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. This process seeks to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification process involves matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.

6 | ADDITIONAL RIGHTS UNDER CALIFORNIA LAW

1. Company’s Non-Discrimination Policy

California Consumers have the right not to be subject to discriminatory treatment by Company for exercising their privacy rights under the California Consumer Privacy Act, and Company will not discriminate on that basis. However, Company may charge a California Consumer a different price or rate or provide a different level or quality of goods or services if the difference is reasonably related to the value provided to the California Consumer by the Consumer’s Personal Information. If Company does so, it will provide Consumers with any legally required notice.

2. Your ‘Do Not Track’ Browser Setting

The Site collects personally identifiable information about your online activities over time and across third-party websites or online services. We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit, including the Site, know that you do not want the sites collecting your personally identifiable information.

7 | THIRD-PARTY LINKS AND SERVICES
We provide links to third-party websites operated by organizations not affiliated with Company. We do not disclose your Personal Information to organizations operating such linked third-party websites. We do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each and every website that you visit. This Privacy Policy applies solely to information collected by Company through the Services.

8 | MINORS UNDER 17 YEARS OF AGE

We respect the privacy of children. Our Services are not designed to attract an audience younger than seventeen (17), and we do not knowingly collect Personal Information from children under seventeen (17). If you are under the age of sixteen (16), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of sixteen (16), and we will work to delete it.

9 | SECURITY

We want you to feel confident about the personal information you provide to us. Therefore, we have implemented a security program to keep information that is transmitted to our systems protected from unauthorized access. Your submissions of information to our secure server are protected by Secure Sockets Layer (SSL) technology, utilized by many popular browsers to safeguard transmissions. This technology allows us to use encryption tools to protect information transmitted between your computer and our server. Through encryption, the personal information you enter, including your name, address, and any other sensitive information (if requested), is converted into code that is then securely dispatched over the Internet. Once our secure server receives your encrypted personal information, it is translated back into its original form and stored in our service provider’s off-line database. After we have received your information, access to it is limited to those with a need to know.

While we strive to protect your personal information, we cannot guarantee the security of any information that is submitted, and you do so at your own risk. We urge you to keep your username, password and any other log-in credentials in a safe place as you share responsibility for maintaining the confidentiality of the information that you submit to us. It is a good practice to sign off your account and close your browser window when you have finished your visit to our online application page.

10 | COOKIES

Cookies may be used on this website. These are pieces of information or data sent to your browser from a web server and stored on your computer’s hard drive for record-keeping purposes. We use this information to analyze traffic patterns and improve our website. If you prefer not to accept cookies, the help portion of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, disabling cookies may result in certain parts of the website not operating correctly or prevent you from taking full advantage of some of the features of our website.

11 | GOOGLE ANALYTICS

We use cookies provided by Google Analytics, a third-party service provider, to assist us in better understanding our site visitors. These cookies collect data tied to a user’s IP address such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting the site. Based on this information, Google Analytics compiles aggregate data about site traffic and site interactions, which we use to offer better site experiences and tools in the future. Google Analytics does not collect any personal information. You can obtain more information about Google Analytics here: http://www.google.com/analytics/learn/privacy.html?rd=1

12 | LINKS TO AND PLUG-INS FROM OTHER WEB SITES OR MEDIA

Our sites may include links from the site to plug-ins (like Facebook) and from sites or applications operated by third parties (“Third Party Sites”). We do not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third Party Site are governed by its privacy policy. It is your choice to connect or enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.

13 | CHANGES TO THIS PRIVACY POLICY
If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal data, we will provide a prominent notice of such changes and the effective date of the changes before making them.

FOR MORE INFORMATION
If you are a California resident, you may visit our Privacy Request Form or request data in compliance with this law by contacting us by phone at 800-805-0795 or by email at privacy@visionmedia.com.

CCPA Request
Vision Media Management
29125 Avenue Paine
Valencia, California 91355

Vision Media CCPA Privacy Data Request Line: 800-805-0795

Requests 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 two requests per customer each year, and we are not required to respond to requests made by means other than through this email address or postal mail address.

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