CCPA Compliance

Last Updated January 15, 2024

Introduction

The California Consumer Privacy Act (CCPA) is a state statute intended to enhance privacy rights and consumer protection for residents of California, United States. The CCPA went into effect on January 1, 2020, and provides California residents with specific rights regarding their personal information.

Stover is committed to protecting your privacy and ensuring compliance with CCPA. This page explains how we comply with CCPA requirements and how California residents can exercise their rights under this law.

Your Rights Under CCPA

If you are a California resident, the CCPA provides you with the following rights regarding your personal information:

Right to Know

  • 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 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 (also called a data portability request).

Right to Delete

  • You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 providers to:
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Sale

You have the right to opt-out of the sale of your personal information. However, we do not sell your personal information. We do not and will not sell personal information to third parties.

If we were to change our practices in the future, we would update this notice and provide you with a clear opt-out mechanism.

Right to Non-Discrimination

  • You have the right not to receive discriminatory treatment by us for exercising any of your CCPA rights. 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.
  • However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your value and contain written terms that describe the program's material aspects.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information").

In particular, we have collected the following categories of personal information from consumers within the last 12 months:

Categories of Personal Information

  • **Identifiers:** Name, email address, postal address, phone number, IP address, and similar identifiers;
  • **Personal Information Categories:** Information that identifies, relates to, describes, or is capable of being associated with a particular individual, including name, signature, physical characteristics, address, telephone number, education, employment, and employment history;
  • **Commercial Information:** Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
  • **Internet or Other Electronic Network Activity:** Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement;
  • **Geolocation Data:** Physical location or movements;
  • **Professional or Employment-Related Information:** Current or past job history or performance evaluations;
  • **Inferences:** Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sources of Personal Information

  • We obtain the categories of personal information listed above from the following categories of sources:
  • Directly from you (e.g., forms you complete, products or services you purchase);
  • Indirectly from you (e.g., observing your actions on our website);
  • From third parties (e.g., service providers, business partners).

How We Use Personal Information

  • We may use or disclose the personal information we collect for one or more of the following business purposes:
  • To fulfill or meet the reason you provided the information;
  • To provide, support, personalize, and develop our website and services;
  • To create, maintain, customize, and secure your account with us;
  • To process your requests, purchases, transactions, and payments;
  • To provide you with support and to respond to your inquiries;
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests;
  • To help maintain the safety, security, and integrity of our website, services, databases, and other technology assets;
  • To 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;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

Sharing Personal Information

  • 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:
  • Service providers who perform services on our behalf;
  • Business partners with whom we collaborate;
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

How to Exercise Your Rights

  • To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  • Completing our data subject request form (link to form if available);
  • Sending an email to privacy@stover.app;
  • Writing to us at the address provided in the Contact section below.
  • 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 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.
  • We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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.

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.

Contact Us

If you have any questions or comments about this notice, our Privacy Policy, 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 do not hesitate to contact us at:

Email: privacy@stover.app