California Privacy Notice

This Notice applies to California residents’ Personal Information (as defined below) we collect when consumers visit our website and when we provide consumers with certain products and services.

The CCPA only applies to information about residents of California.  If you are not a resident of California, you may submit a request and we may process it, as described in this Notice and our general privacy policy, even though the CCPA does not require us to do so.  In accepting, processing, and responding to requests by individuals who are not California residents, we will apply all the same limitations and exceptions under the CCPA to those requests as apply to requests made by California residents.  We reserve the right to change or stop the practice of accepting requests from U.S. individuals who are not California residents.

In addition, updated CCPA requirements went into effect on January 1, 2023, for applicable product and services related to employee and business-to-business Personal Information.  As a result, this Notice also applies to employees, applicants for employment, and independent contractors, who are California residents.

The CCPA defines “Personal information” as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household.  Under the CCPA, “Personal Information” further includes “Sensitive Personal Information” such as social security number, driver license number, state identification card, passport number, financial data, genetic data, biometric data, precise geolocation, and racial and ethnic origin, content of consumer communications (email, mail, or text), unless the business is the intended recipient, genetic data, and information collected concerning a consumer’s health, sex life, or sexual orientation.

Below are the categories of Personal Information that we may have collected or shared for a business purpose in the last twelve (12) months, as permitted by law and depending on the product or services you receive:

We collect the foregoing information directly or indirectly from you and/or your authorized representatives in connection with the provision of our products and services, through automatic collection from your web browser when you visit our website or access our coaching platform, when you interact with our sales and support teams, when you provide information in connection with your employment or prospective employment with Optify, when you attend one of our marketing events, from public sources (e.g., social media sites) and from other sources such as third-party vendors.

See “Personal data we collect” in our general privacy notice to learn more.

We use Personal Information to provide our website and our products and services and to accomplish our business and commercial purposes and objectives, including the following:

• To provide you with access to, and use of, our websites, products, and services.
• To respond to your request for information, orders, or support.
• As business contact information of clients, prospects, partners, and suppliers for commercial relationships.
• To perform security functions, including to detect security breaches, protect against fraud and malicious activities, and take action against wrongdoers;
• To provide information about visitors to our sites and their locations.
• To develop and improve our products and services and for compliance;
• For marketing, sales, analytics, and communicating with you.
• As described to you when collecting your personal information or subsequently agreed to by you, and as otherwise permitted under the CCPA.

We use Sensitive Person Information for the following purposes:

• To run secure and safe events.
• In connection with you employment or prospective employment with Optify.
• To respond to data rights requests.

See “How we use the information we collect” in our general privacy notice to learn more.

Within the last 12 months, we may have shared Personal Information within each of the following categories, with these third parties:

• Service providers and vendors to perform functions and provide services, such as website and database hosting and maintenance, data analytics, marketing automation, billing and payment processing, and other activities relating to client relationships, marketing and marketing research, error monitoring, debugging, and information technology and related infrastructure;
• Professional employment organization for managing recruitment processes;
• Other third parties to whom you or your authorized agent authorize us to share personal information in connection with our products and services; and
• We share personal information to the extent necessary to provide Services and to accomplish our business and commercial purposes and objectives, and we require these third parties to maintain the privacy and security of the Personal Information they access.

We do not sell or rent your personal information to unaffiliated third parties, such as sellers of goods or services, for their own business or commercial purposes.  We may share anonymous or aggregated information with third parties to help deliver products, services and content and for other purposes.

See “Sharing and disclosure of personal data” in our general privacy notice to learn more about the categories of Personal Information we disclose, and the categories of third parties to whom your Personal Information is disclosed.

As a California resident, you have the right to:

1. Know your Personal Information: The CCPA permits users of our Services who are California residents to request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request, including the categories of Personal Information collected, the categories of sources from which the Personal Information is collected, the specific pieces of Personal Information we have collected, the business or commercial purpose for collecting Personal Information, the categories of Personal Information that we disclose to third parties and the categories of third parties with whom we share your Personal Information. See further instructions for receiving your Personal Information, below.
2. Request Deletion or Rectify your Personal Information: You may request that we delete or correct the Personal Information that we have collected. We will delete your information unless it is necessary for purposes permitted by CCPA.
3. Opt out of Sale or Sharing of your Personal Information. The CCPA gives you certain rights to opt-out of the sale of any of your Personal Information. Since we never sell, rent or trade your Personal Information, you need take no further option to opt-out from the sale of your Personal Information.
4. Limit the Use or Disclosure of Sensitive Personal Information:

• We generally do not collect sensitive personal information outside of the situations described above. We only use and disclose your SPI in ways that are necessary to perform our services, in ways that are reasonable and proportionate to the expectation of an average consumer.
• In CCPA, you have the right to limit the use and disclosure of your SPI if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.

5. Consent to new uses. Before we use Personal Information for any purpose not previously disclosed to you, we will notify you of this new use and obtain explicit consent from you to use it for this purpose.

Non-discrimination. If you choose to exercise any of these rights, we will not deny services to you or provide different quality of services, unless that difference is reasonably related to the value provided by your data.

Authorize an Agent. You may designate an agent to make a request under the CCPA on your behalf.  To do so, please provide the agent a written letter appointing the agent, acknowledged before a notary public.  The agent must furnish a copy of the appointing letter to us when taking action under the CCPA on your behalf.