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Last updated: March 25, 2020
This policy is specific and applies only to web visitors who are California residents, under the meaning of Section 17014 of Title 18 of the Cal. Code of Regulations. Under the California Consumer Privacy Act of 2018 (“CCPA”), up to twice in a twelve (12) month period, a consumer has the right to request that a business disclose what personal information it collects, uses, discloses, and sells. Please read this policy carefully as it contains important information regarding our collection, disclosure, and sale of personal information, in addition to instructions on how to exercise your rights regarding your personal information.
We collect, and have collected the following personal information about individuals interacting with our email advertisements in the preceding 12 months:
| Categories of Personal Information | Specific Types of Personal Information Collected |
|---|---|
| Identifiers, or information that Identifies, relates to, describes, or is capable of being associated with, a particular individual | First name; last name; Email address; Internet Protocol address; Postal address |
| Internet or other electronic network activity information | Web browser type and version; Geographic region based on web browser type; Behavioral data( opens, clicks) |
| Commercial information | Products or services purchased, obtained, considered |
| Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, behaviour, etc. | Inferences about an individual’s prpensity to respond to a particular email advertisement |
The above personal information is required to provide email advertising services to you, and to allow you to access and interact with email advertisements. The above personal information is used to track consumer interaction with our email advertisements (counting ad impressions, verifying positioning, and verifying quality of ad impressions).
We collect the above personal information directly from you when you open and/or click on the email advertisements which we send you, as well as if you request to unsubscribe from receiving future email advertisements from us. We also collect the above personal information through data analytics providers, operating systems and platforms, and consumer data resellers/brokers.
If you elect to unsubscribe from receiving future email advertisements from us, we may disclose your email address to third party service providers, advertisers and others in order to comply with 15 U.S.C. 7701.
We have NOT sold your personal information to third parties for any business or commercial purpose within the preceding 12 months, and we will NOT sell your personal information to third parties. There are no financial incentives to disclose. Please note that we do NOT sell the personal information of minors under 16 years of age, without affirmative authorization.
A “request to know” is a request related to the personal information that a business has about such consumer. It may include a request for any or all of the following:
1) specific pieces of personal information that we have about you;
2) categories of personal information we have collected about you;
3) categories of sources from which the personal information was collected;
4) categories of personal information that we have sold or disclosed for a business purpose about you;
5) categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
6) the business or commercial purpose for collecting or selling the personal information.
The CCPA permits requests to know from the same consumer up to twice in a twelve (12) month period.
To submit a request to know, please click here: Request to know or email office@urbanpulsemanagement.com. To process your request, you will be required to submit your name and email address in conjunction with your request. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If we are able to identify your email address in our records, then you will receive an email confirmation and instructions for verifying your identity. If you elect to use an authorized agent to exercise your right to submit a request for information, proof of your consent to utilize such authorized agent as well as verification of your own identity may be required before processing the request. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.
You have the right to request the deletion of any personal information which we have collected about you, or which we maintain. To submit a verifiable request to delete, please click here: Request to delete or email office@urbanpulsemanagement.com. To process your request, you will be required to submit your name and email address in conjunction with your request. If we are able to identify your email address in our records, then you will receive an email confirmation and instructions for verifying your identity. The information which you provide will be used to verify your request and to attempt to identify you within our data records. If you elect to use an authorized agent to exercise your right to submit a request for information, proof of your consent to utilize such authorized agent as well as verification of your own identity may be required before processing the request. The information which you submit in conjunction with your request to know will be used for the express purposes of verification and providing you with responsive information to your request, if required.
A two-step process must be utilized for online requests to delete, whereby you clearly submit your request to delete, and second, you separately confirm that you want your personal information deleted.
To the extent that your personal information is necessary for us to maintain for a reason delineated in Cal. Civ. Code § 1798.105(d), including but not limited to complete a transaction for which the personal information was collected, provide a good or service you have requested, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug, etc., or to comply with a legal obligation, such a fulfilling a request to optout under 15 U.S.C. 7701, we are not required to comply with your request for deletion. For instance, we are not required to delete personal information which is necessary to maintain suppression files for those individuals who have opted out of receiving email marketing from us. If we are unable to verify your request, we will notify you as well.
California affords consumers with the right not to receive discriminatory treatment by a business for the exercise of their privacy rights conferred by the CCPA. This means that you cannot be denied goods or services; be charged different prices or rates; be provided with a different level or quality of goods or services; or have it suggested that you will receive a different price or rate or different level or quality of goods or services. Notwithstanding the above, a business can charge a consumer a different rate or price, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to the consumer by the consumer’s data. Further, notwithstanding the above, a business may offer financial incentives for the collection of personal information, the sale of personal information, or the deletion of personal information, and may also offer a different price, rate, level, or quality of goods or services to the consumer if that different is directly related to the value provided to the consumer by the consumer’s data.
If you have any questions or concerns regarding your California privacy rights, or our privacy practices, please click here: Contact us or email office@urbanpulsemanagement.com. Further, if you have a disability which interferes with your ability to access this policy, accommodations can be made to present the policy in an alternative format, to assist you. If you would like to receive this information in another format that is accessible to your needs (for example: audio, large print, etc.) please email office@urbanpulsemanagement.com
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