CCPA Privacy Notice
This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of CorporateGift.com, Inc. ("CorporateGift"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
CORPORATEGIFT.COM, INC. ACTING AS A SERVICE PROVIDER.
We collect your personal information for the Service pursuant to a contract we have with a commercial client (our “Client”). In such instances, we may be acting as a “service provider” and are obligated to process the personal information we collect or are provided in connection with the Service in accordance with instructions from or the contract with our Client, which is the “business” ultimately responsible for determining how your personal information will be handled.
Accordingly, if you are using the Service in connection with your role as an employee of our Client, or by virtue of some other relationship with our Client, we encourage you to review that Client’s privacy notice to understand the full scope of how your personal information will be handled. Further, in any case where we are acting as a service provider to a Client, if you or your wish to exercise any rights that may be available to you under certain data privacy laws (for example, the right to access or deletion under the CCPA if you are a resident of California as described below), you should direct your request to our Client, who is the party responsible for receiving, assessing, and responding to your requests, as we do not have any legal obligation, and, notwithstanding anything in this Privacy Notice to the contrary, may elect not to respond to your requests. If you are not certain whether we are acting as a service provider to a Client in your particular circumstance, we urge you to contact us through one of the methods described at the end of this Privacy Notice.
When we use the term personal information in this notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:
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Consumer information that is lawfully made available from federal, state, or local government records.
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Consumer information that is de-identified or aggregated.
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Information generally excluded from the CCPA’s scope.
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PERSONAL INFORMATION COLLECTED BY CORPORATEGIFT.COM, INC. AS A SERVICE PROVIDER
In the past 12 months, we may have collected and shared the following types of personal information from about users of our Service.
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Categories of Personal Information |
Examples/Description |
Categories of Sources of Personal Information |
Business or Commercial Purposes of Personal Information |
Categories of 3rd Parties we share Personal Information with |
|
A. Identifiers. |
Full name, postal address, online identifier, Internet Protocol address, email address, account name, other similar identifiers, date of birth |
Directly from you (e.g., when you submit an application, create an account, send a gift or e-gift or make an inquiry to a service center) Indirectly from you (in case you are a gift recipient) |
• Provide services to you •Compliance/security monitoring and screening • Communications with you about our products and services |
Vendors that we engage in connection with the services; Vendors who provide support in operating, assessing, and improving the performance of our website |
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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
Full name, postal address, telephone number, bank account number, credit card number, any other financial information, expiration date card code; card verification number; |
Directly from you (e.g., when you submit an application, create an account, send a gift or e-gift or make an inquiry to a service center) Indirectly form you (in case you are a gift recipient) |
• Provide services to you •Compliance/security monitoring and screening • Communications with you about our products and services |
Vendors that we engage in connection with the services; Vendors who provide support on operating, assessing, and to improve the performance of our website |
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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, sexual orientation, gender identity or expression, veteran or military status, genetic information |
Non-applicable |
Non-applicable |
Non-applicable |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies |
Directly from you (e.g., when you give a gift or e-gift) Indirectly form you (in case you are a gift recipient) |
• Provide services to you •Compliance/security monitoring and screening • Communications with you about our products and services |
Vendors that we engage in connection with the services; Vendors who provide support on operating, assessing, and to improve the performance of our website |
|
E. Biometric information. |
Genetic, physiological, behavioural, 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 |
Non-applicable |
Non-applicable |
Non-applicable |
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F. Internet or other similar network activity. |
Information on a consumer's interaction with the CorporateGift website, application, or advertisements, collecting time of visit, pages visited, and time spent on each page of the website, referring site details (such as the URL a user came through to arrive at this site), type of web browser, type of operating system (OS), Flash version, JavaScript support, screen resolution, and screen colour processing ability, network location and IP address, data on visits and behaviour on the site; screen recording and heatmaps; track mouse movement and clicks; keyboard activity; device model, operating system, unique identifiers, browser type, mobile network information, and the Internet Protocol (IP) address; data from cookies |
Indirectly from you |
To operate, assess activity of, and improve our website and the services they support |
Vendors who provide support in operating, assessing, and to improving the performance of our website |
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G. Geolocation data. |
Physical location |
Indirectly from you |
Fraud detection in payment |
Vendors that we engage in connection with the services |
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H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information |
Non-applicable |
Non-applicable |
Non-applicable |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations |
Non-applicable |
Non-applicable |
Non-applicable |
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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 |
Non-applicable |
Non-applicable |
Non-applicable |
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K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes |
Non-applicable |
Non-applicable |
Non-applicable |
We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes. We do not sell personal information to any 3rd parties and have not done so in the preceding 12 months.
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HOW CORPORATEGIFT.COM, INC. USES YOUR PERSONAL INFORMATION AS A SERVICE PROVIDER?
We may use, or disclose the personal information we collect as a service provider solely for the purpose of the fulfilment of the contract with the Client. The use of the personal information by CorporateGift as a service provider may be divided into following processes:
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Processing of users’ personal information as Marketplace and Gifting Platform software users acting on behalf of Client during account registration;
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Processing of users’ and gift recipients’ personal information when ordering gifts;
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Processing of users’ personal information acting on behalf of Client during the payment process;
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Processing of users’ personal information during user account management;
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Processing of users’ and gift recipients’ personal information when ordering eGifts;
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Processing of users’ and gift recipients’ personal information during gift packaging and customization in CorporateGift, Inc. warehouse;
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Processing of users’ and gift recipients’ personal information during gift delivery;
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Processing of users’ and gift recipients’ personal information during handling of complaints;
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Processing of users’ and gift recipients’ personal information during handling of users’ or gifts recipients’ inquires;
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Processing of users’ personal information in the process of providing account services;
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Processing of users’ personal information through the “live chat” functionality;
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Processing of users’ personal data through the “Contact us” functionality;
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Processing of users’ personal data through the “Notification out of stock” functionality;
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Processing of users’ personal data through the “Notify me” functionality;
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Processing of users’ personal data in connection with the CorporateGift, Inc. accounts on: Facebook, Instagram, Twitter, LinkedIn;
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.
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HOW DOES CORPORATEGIFT.COM, INC. SHARE PERSONAL INFORMATION ACTING AS SERVICE PROVIDER?
CorporateGift acting as a service provider may disclose your personal information to 3rd parties involved in the processing of your personal information, including:
a) Vendors and service providers, including data analytics and advertising platforms, for the purpose of marketing and advertising our products and services to you;
b) 3rd parties integrated into our services;
c) 3rd parties as required by law and similar disclosures.
When we disclose your personal information to a 3rd party, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.
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CORPORATEGIFT.COM, INC. ACTING AS A BUSINESS
Under limited circumstances, CorporateGift is acting as a business. According to CCPA, business means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that collects consumers’ personal information, or on the behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information or any entity that controls or is controlled by a business, as defined in precedent sentence and that shares common branding with the business.
CorporateGift is acting as a business in the following situations:
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Processing of Client representatives’ personal information upon the conclusion of the Agreement regarding the use Marketplace and Gifting Platform software;
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Processing of users’ and gift recipients’ personal information due to the defence against claims;
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Processing of personal information in connection with the CorporateGift accounts on: Facebook, Instagram, Twitter, LinkedIn;
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Processing of personal information due to the “Become a merchant” functionality;
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Processing of personal information due to the “Request a demo” functionality;
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Processing of personal information due to “Submit an RFP” functionality;
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Processing of personal information in other situations than described in items a)-f);
In the past 12 months, we may have collected and shared the following types of personal information from or about you:
|
Categories of Personal Information |
Examples/Description |
Categories of Sources of Personal Information |
Business or Commercial Purposes of Personal Information |
Categories of 3rd Parties we share Personal Information with |
|
A. Identifiers. |
Full name, email address, telephone, job title; Internet identifiers |
Directly from you (e.g., when you submit an application or make an inquiry to a service center) |
Communications with you about our products and services |
Vendors that we engage in connection with our services; Vendors who provide support in operating, assessing, and improving the performance of our website |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
Full name, email address, telephone, job title |
Directly from you (e.g., when you submit an application or make an inquiry to a service center) |
Communications with you about our products and services |
Vendors that we engage in connection with our services; Vendors who provide support on operating, assessing, and improving the performance of our website. |
|
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, sexual orientation, veteran or military status, genetic information |
Non-applicable |
Non-applicable |
Non-applicable |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Non-applicable |
Non-applicable |
Non-applicable |
|
E. Biometric information. |
Genetic, physiological, behavioural, 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 |
Non-applicable |
Non-applicable |
Non-applicable |
|
F. Internet or other similar network activity. |
Network location and IP address, data on visits and behaviour on the site; unique identifiers, browser type, mobile network information, and the Internet Protocol (IP) address; data from cookies |
Indirectly from you |
To operate, assess activity on, and improve our website and the services they support |
Vendors who provide support on operating, assessing, and to improve the performance of our website |
|
G. Geolocation data. |
Physical location |
Non-applicable |
Non-applicable |
Non-applicable |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information |
Non-applicable |
Non-applicable |
Non-applicable |
|
I. Professional or employment-related information. |
Job title |
Directly from you (e.g., when you submit an application or make an inquiry to a service center) |
Communications with you about our products and services |
Vendors that we engage in connection with the services |
|
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. |
Non-applicable |
Non-applicable |
Non-applicable |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes |
Non-applicable |
Non-applicable |
Non-applicable |
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YOUR RIGHTS AS CALIFORNIA RESIDENT
The CCPA grants Consumers with certain rights, which are subject to certain limitations and exceptions. This section describes these rights. If we are not able to complete some or all of a Consumer’s verifiable request, we will communicate the reason to the Consumer in writing. When legally required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time. The following rights are granted to You as a California resident:
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CATEGORIES OF THE RIGHTS |
DESCRIPTION OF THE RIGHTS |
HOW TO EXERCISE THE RIGHT |
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1) Right to access to the personal information and Right to be accustomed with the personal information transferred for the business purpose |
You have the right to request that we disclose certain information regarding our business practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:
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To exercise the right to access to the personal information and right to be accustomed with the personal information transferred for the business purpose, the right request deletion, right to non-discrimination, right to opt out of the sale of your personal information (if applicable), or other California Privacy Rightsplease submit a verifiable consumer request to us by either: |