CCPA Privacy Notice
Effective Date: January 1, 2023
Last Reviewed on: January 20, 2023
This CCPA/CPRA Privacy Notice for California Residents (this “Privacy Notice”) supplements the information contained in Sectigo’s Privacy Policy (https://www.sectigo.com/privacy-policy) and applies solely to all visitors, users, and others, as well as Sectigo employees and job applicants who reside in the State of California (“consumers”, “employee”, “job applicant”, “contractor”, or “you”).
We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), (collectively, “CCPA/CPRA”) and any terms defined in the CCPA/CPRA have the same meaning when used in this Privacy Notice. All other terms, unless otherwise specified in this Privacy Notice, shall have the definitions assigned to them in the Privacy Policy.
As of January 1, 2023, the CPRA expands the CCPA so that it provides the same data privacy rights that it provides to consumers to employees and job applicants, or other similarly situated individuals.
Where noted in this Privacy Notice, the CCPA/CPRA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular employee, job applicant, consumer, household, or device (“personal information”). The CPRA adds a second category of personal information, referred to as sensitive personal information (“sensitive personal information”). Sensitive personal information is personal information that reveals: (i) a consumer’s social security, driver’s license, state identification card, or passport number; (ii) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (iii) a consumer’s precise geolocation; (iv) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (vi) a consumer’s genetic data; (vii) the processing of biometric information for the purpose of uniquely identifying a consumer; (viii) personal information collected and analyzed concerning a consumer’s health; or (iix) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Neither Personal information nor Sensitive Personal Information includes:
In particular, we have collected the following categories of personal information from consumers, employees, job applicants, and contractors within the last twelve (12) months:
Category |
Examples |
Possibly Collected |
|
Consumer |
Employee/ Job Applicant |
||
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
YES |
YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
YES |
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
NO |
YES |
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
NO |
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
YES |
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
YES |
YES |
G. Geolocation data. |
Physical location or movements. |
NO |
YES |
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
YES |
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
NO |
YES |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
YES |
K. Inferences drawn from other personal information. |
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
YES |
We obtain the categories of personal information listed above from the following categories of sources:
If you are a consumer, we do not collect any of your sensitive personal information.
If you are an employee, job applicant, or contractor we may collect the following sensitive personal information:
We may use or disclose the personal information we collect for one or more of the following purposes:
If you are a consumer, we do not collect your sensitive personal information.
If you are an employee or job applicant, we may use or disclose your personal, and or, sensitive personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information, or sensitive personal information, or use the personal information, or sensitive personal information, we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Our employees, contractors, and prospective employees (job applicants) that live in California have the same rights over their employment and job application data as consumers. We do not sell or share any employee or job applicant data with anyone other than third-party service providers necessary to complete requested services (e.g. payroll and benefits management, background check vendors).
In the preceding twelve (12) months, Sectigo has disclosed the following categories of consumer personal information for a business purpose:
In the preceding twelve (12) months, Sectigo has disclosed the following categories of employee, job applicant, and/or contractor personal information for a business purpose:
In the preceding twelve (12) months, Sectigo has disclosed the following categories of employee, job applicant, and/or contractor sensitive personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, Sectigo has not sold or shared personal information for purposes beyond those authorized by the CCPA/CPRA. Relatedly, we do not have actual knowledge that we sell or share personal information of California consumers under 16 years of age.
The CCPA/CPRA provides consumers, employees, and job applicants (California residents) with specific rights regarding their personal information, and, where applicable, sensitive personal information. This section describes your CCPA/CPRA rights and explains how to exercise those 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 request (see CORRECTION REQUEST RIGHTS
You have the right to request that we correct any of the personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Error! Not a valid bookmark self-reference.), we will correct (and direct our service providers to correct) your personal information, or sensitive personal information, in our records, unless an exception applies.
We may deny your correction request if:
EXERCISING ACCESS, DATA PORTABILITY, DELETION, AND CORRECTION RIGHTS), we will disclose to you:
You have the right to request that we delete any of your personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see CORRECTION REQUEST RIGHTS
You have the right to request that we correct any of the personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Error! Not a valid bookmark self-reference.), we will correct (and direct our service providers to correct) your personal information, or sensitive personal information, in our records, unless an exception applies.
We may deny your correction request if:
EXERCISING ACCESS, DATA PORTABILITY, DELETION, AND CORRECTION RIGHTS), 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:
You have the right to request that we correct any of the personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Error! Not a valid bookmark self-reference.), we will correct (and direct our service providers to correct) your personal information, or sensitive personal information, in our records, unless an exception applies.
We may deny your correction request if:
To exercise the access, data portability, deletion, correction rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized 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. The verifiable consumer request must:
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.
We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 45 or 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable 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 do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate and/or retaliate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA/CPRA 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.
We will maintain certain consumer data for as long as is mandated by our industry requirements. As of the publication of this CCPA/CPRA Privacy Notice, we must maintain the information used to validate a certificate for at least seven (7) years after the termination of a subscriber agreement,
We retain employee personal information, and sensitive personal information, for the duration of the employment relationship with us and longer as may be required by applicable laws or necessary for our legitimate business purposes.
We retain job applicant personal information and sensitive personal information indefinitely.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Website and update the Privacy Notice effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Privacy Notice, the ways in which Sectigo collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (888) 266-6361
Website: https://www.sectigo.com
Email: [email protected]
Postal Address:
Sectigo, Inc. c/o Sectigo Limited
Attn: Legal Department
5 Becker Farm Road, Suite 300
Roseland, NJ 07068
United States