CALIFORNIA PRIVACY RIGHTS

August 6, 2020

 

FOR CALIFORNIA RESIDENTS 

CALIFORNIA PRIVACY RIGHTS 

Last Modified:  March 15, 2023

 

 

CALIFORNIA SHINE THE LIGHT LAW

 

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at the address provided below.

 

For all such requests, please indicate “CA Shine the Light” in the subject field of your request and include the name of the HarperCollins US Service with respect to which you are requesting the information. You must also include your full name, email address, street address, city, state, and zip code.

 

NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA and CPRA.  The CCPA and CPRA shall be collectively referred to herein as the “CPRA”.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information by HarperCollins Christian:

 

CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU, WHY AND HOW

Summarized in the table below are the categories of personal information we may collect about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.

 

Categories of information collected Purposes of collection

 

 

Sources of personal information
Identifiers Performing Services; Auditing; Short-term Use; Data Security & Fraud Prevention; Research and Development; Quality and Safety; Commercial Interests Services Use; Affiliates and Partners; You
Commercial Data Performing Services; Short-term Use; Commercial Interests Services Use; Affiliates and Partners; You
Financial Data Performing Services Services Use; Affiliates and Partners; You
Internet Data Performing Services; Auditing; Short-term Use; Data Security & Fraud Prevention; Research and Development; Quality and Safety; Commercial Interests Services Use; Affiliates and Partners; You
Geo-location Data Performing Services Services Use
Inference Data Performing Services; Commercial Interests; Short-term Use Affiliates and Partners; Service Use
Protected Data Performing Services; Commercial Interests; Short-term Use Affiliates and Partners; Service Use; You
Profile Data Performing Services; Commercial Interests; Short-term Use Affiliates and Partners; Service Use; You
Associated Data Performing Services; Commercial Interests; Short-term Use Affiliates and Partners; Service Use

 

More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise forth the Information We Collect and Obtain and How We Use the Information We Obtain Sections of our Privacy Notice.

Categories of Personal Information Collected:

  • Identifiers (such as your contact information (name, email address, postal address, phone number) or unique personal identifiers (wireless device ID, cookies, IP address) (“Identifiers”);
  • Commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
  • Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”);
  • Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”);
  • Geo-location information (such as city, state and zip code associated with your IP address or derived through Wi-Fi triangulation; and with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices (“Geo-location Data”);
  • Inference information about you (such as preferences, characteristics, and behaviors) (“Inference Data”);
  • Legally protected classifications (such as gender) (“Protected Data”);
  • Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes) (“Profile data”); and
  • Information that identifies or can be reasonable associated with you (“Associated Data”).
  • Sensitive personal information (such as account log-in; debit card or credit card number in combination with any required security or access code, password or credentials; religious or philosophical beliefs; contents of mail, email and text messages) (“Sensitive Personal Information”)

Business or Commercial Purposes for which We Collected or Disclosed Personal Information: 

  • 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 (“Performing 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 (“Auditing”);
  • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”);
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
  • debugging to identify and repair errors that impair existing intended functionality (“Repairs”);
  • undertaking internal research for technological development and demonstration (“Research and Development”);
  • 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 (“Quality and Safety”); and
  • to advance the commercial or economic interests of the Company, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”).

Categories of Sources from which We Collected Personal Information:

  • Directly from you (“You”);
  • From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; public data bases; consumer data resellers; researchers; payment processors; and surveys)(“Affiliates and Partners”); and
  • Through your use of the Services (“Services Use”).

 

HOW WE SELL/SHARE AND DISCLOSE YOUR INFORMATION

We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes.  The chart below explains the categories of information that we may share with third parties and the categories of those parties

Third Parties with which we share information and why Categories of information shared
Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver products and services to you, and enhance our products, services, and your customer experience, consistent with our Privacy Notice. Those businesses may also use your information for their own purposes, including marketing purposes.

 

·       All categories of information we collect may be shared with our affiliates
Third Party Partners for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. For example, if you participate in our Reader Service program, then we may share information with third parties for their marketing and other purposes.

 

·       Identifiers

·       Commercial Data

·       Internet Data

Third Parties for Legal Requirements and Proceedings.  We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.

 

·      Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements
Third Parties for the Protection of our Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary to prevent physical harm or financial loss.

 

·      Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements
Third Parties in Business Transfers.  We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets. ·      Any or all categories of information may be shared with third parties in a business transaction, depending on the specific transaction
Third-Party Online Advertisers and Ad Networks.  As discussed in the Interest-Based Advertising Section  of  Privacy Notice, the Services may rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads. ·      Identifiers

·      Internet Data

·      Geolocation Data

 

Internet Services Providers. In connection with the provision of the Services, we may share information with companies that provide internet services. ·      Identifiers

·      Internet Data

·      Geolocation Data

·

Data Analytics Providers.  We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business. ·      Identifiers

·      Internet Data

·      Geolocation Data

Operating Systems and Platforms. We may share information with software companies that power your devices   and companies that provide common tools/information for software or apps about software or app consumers. ·      Identifiers
List Rental Services. Where permitted by law, we may share information with list rental services for such List Rental Services’ marketing or commercial purposes.

 

·      Identifiers

·      Commercial Data

 

CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES

In addition to rights of access, correction and deletion, as described in the Privacy Notice, California Consumers may have certain additional rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure and portabilityYou may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you for the time period from the date of your request to January 1, 2022:

  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected or sold the personal information;
  • the categories of third parties with whom we shared the personal information;
  • the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose; and
  • the specific pieces of personal information we obtained from you in a format that is easily understandable, and to the extent technically feasible, in a structured commonly used, machine-readable format.

The right to nondiscriminationWe will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

The right to opt-out of the sale or sharing of your personal information. You have the right to opt out of the sale or sharing of your personal information. California law broadly defines sale such that it may include allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising.   

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information.

If you would like to opt out, you may do so as outlined on the following page: Limit the Use of My Sensitive Personal Information 

How to exercise your access, correction and deletion rights.

California residents may exercise their California privacy rights by submitting your request via our online webform or by contacting us at 1-800-277-3110.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will provide a summary of this information.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CPRA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
  • Where you have requested that we delete personal information that we have collected from you, we will inform you whether or not we were able to comply with your request. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

Authorized Agents

You may also designate an agent to make requests to exercise your rights under CPRA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

RETENTION OF PERSONAL DATA

We will retain your personal data for as long as needed for the uses set out in our Privacy Notice, or while there is a legitimate reason for doing so.  For example, if you have created an account with us or made a purchase online, we will retain your information for the active life of your account until you terminate your account, so we can complete the purchase transaction or until you otherwise request deletion of your data.  In all other cases we will retain records as appropriate to the data category and in line with any legal obligations.

HOW TO CONTACT US

If you are a California Consumer, to submit a request, please contact us via our online webform or by contacting us at 1-800-277-3110. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

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