Our California Consumer Privacy Act Notice

Our California Consumer Privacy Act Notice

 

As required by the California Consumer Privacy Act of 2018 (“CCPA”), MYNDIFYTM (“Company”, “we,” “us”, or “our”) provides this California Consumer Privacy Act Notice (“CCPA Notice”). This CCPA Notice supplements our Privacy Policy and applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the meaning set forth in the CCPA.

 

1.      Personal Information Collected

We collect the following categories of personal information that relates to, describes, references, can be associated with, or reasonably linked, directly or indirectly, with a particular consumer or device (“personal information”). We have collected the following categories of personal information from consumers within the last twelve months as indicated with an “X” below:

☒  A. Identifiers. Examples: to a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.

☒  B. Personal information as defined in the California customer records law. Examples: name, contact information, education, employment, employment history and financial information.

☒ C. Characteristics of protected classifications under California or federal law. Examples: age, ethnicity, citizenship, marital status, physical or mental illness or disabilities, gender, veteran status, religion, or creed,

☐ D. Commercial information. Examples: as transaction information, purchase history, financial details, and payment information.

☐ E. Biometric information. Examples: fingerprints and voiceprints.

☒ F. Internet or other electronic network activity information. Examples: browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

☒ G. Geolocation data. Examples: device location.

☒ H. Audio, electronic, visual, and similar information. Examples: images and audio, video or call recordings created in connection with our business activities.

☐ I. Professional or employment-related information. Examples: Occupation, employer information

☐ J. Education information subject to the federal Family Educational Rights and Privacy Act. Examples: Education level, schools attended, and student records.

☒ K. Inferences drawn from any of the personal information, as listed above. Examples:  Creating a profile or summary about a persons’ preferences and characteristics. characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Personal information does not include Publicly available information from government records;  De-identified or aggregated consumer information; and Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act (CMIA) or clinical trial data and personal information covered by sector-specific privacy laws, including but not limited to the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

We collect the categories of personal information listed above directly and indirectly from the following categories of sources:

  • Users and their agents. For example, from documents that our Users provide related to the services we provide and information we collect from our Users in the course of providing services;
  • From activity on our website (https://MYNDIFYapp.com). For example, from submissions through our App or website, and website usage details collected automatically;
  • Public and publicly available sources;
  • Third-party resellers and referral partners, vendors, data suppliers and service providers;
  • Partners with which we offer co-branded services or engage in joint event or marketing activities;
  • Social networks;
  • News outlets and related media; and
  • Any organization with which you are employed or affiliated.

We share this personal information with our: service providers, suppliers, vendors; agents and representatives; joint venture partners; other entities offering products and services that may be of interest to you; resellers, distributors, referral partners and integrators; administrators authorized by your organization (if you access our services through a subscription administrated by your organization); licensors of third-party applications (if you access a third-party application on our services through a license agreement with the licensor); and other parties where required by law or to protect our rights.

 

2.      Use of Personal Information

We may use or disclose the personal information we collect to operate, manage, and maintain our business, to provide our products and services, to communicate with you, for vendor management, and our legitimate business purposes, including the following legitimate business purposes:

  • Respond to the reason for which the information is provided. For example, if you provide us with your email to respond to your question, we will use that information to email you a response.
  • Provide the information or services that you request from us.
  • Provide email alerts, shipment updates and other notices concerning our services, or news or events that may be of interest to you.
  • Meet our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • Improve our website and present its contents to you.
  • Testing, research, analysis, and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our Users, or others.
  • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

 

3.      Personal Information Disclosed

We may disclose your personal information to a third party for business purposes. If we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to keep both that personal information confidential and to not use it for any purpose other than performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose, as indicated with a “X” mark: 

☐  A. Identifiers. Examples: to a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.

☐  B. Personal information as defined in the California customer records law. Examples: name, contact information, education, employment, employment history and financial information.

☐ C. Characteristics of protected classifications under California or federal law. Examples: age, ethnicity, citizenship, marital status, physical or mental illness or disabilities, gender, veteran status, religion, or creed,

☐ D. Commercial information. Examples: as transaction information, purchase history, financial details, and payment information.

☐ E. Biometric information. Examples: fingerprints and voiceprints.

☐ F. Internet or other electronic network activity information. Examples: browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

☐ G. Geolocation data. Examples: device location.

☐ H. Audio, electronic, visual, and similar information. Examples: images and audio, video or call recordings created in connection with our business activities.

☐ I. Professional or employment-related information. Examples: Occupation, employer information

☐ J. Education information subject to the federal Family Educational Rights and Privacy Act. Examples: Education level, schools attended, and student records.

☐ K. Inferences drawn from any of the personal information, as listed above. Examples:  Creating a profile or summary about a persons’ preferences and characteristics. characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

☒ In the previous twelve months, COMPANY has not sold any personal information to third parties within the scope of the application of the CCPA.

4.      Your Rights

Under the CCPA, California Residents are granted specific rights regarding their personal information. These are your CCPA rights and how to exercise those rights.

Access to Specific Information and Data Portability 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 previous twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you – your Data Portability Request.
  • If we sold or disclosed your personal information for a business purpose, two separate disclosure lists:

o Sales: identifying the personal information categories that each category of recipient purchased; and

o Business purpose: identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we delete personal information we collected from you subject to certain exceptions. You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. COMPANY does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

5.      How to Request a Disclosure or Deletion.

You may request the disclosure or deletion of your personal information described above [This can also be a portal or link in membership are for submitting requests].

You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or California Constitution.

6.      Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Emailing us at: privacy@myndifyapp.com with California Privacy Request in the subject line.
  • Via our website: MYNDIFYapp.com

Only you or a person registered with the California Secretary of State that you authorize 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:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

7.      Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer 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 consumer 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.

8.      Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

9.      Changes to Our Privacy Notice

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 notify you by email or through a notice on our website homepage.

 

10.  Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under California law. Please contact us at:

  • Calling us at: 347-674-1512 
  • Emailing us at: privacy@myndifyapp.com

 

11.  Changes

We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.

Effective Date: January 1, 2024

Last updated: April 12, 2024