NextGate California Privacy Disclosure

Effective: February 15th 2022.

This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like us that receive information from more than fifty thousand California consumers to provide certain information to them. We fully describe our practices to all our members and visitors in our Privacy Policy, but use this separate notice to ensure that we meet the CCPA’s requirements. This notice contains the following four parts:

  1. We Do Not Sell Your Personal Information
  2. Your Rights Under the CCPA
  3. The CCPA Categories of Personal Information We Collect and the Sources
  4. The CCPA Categories of Personal Information We Share for a “Business Purpose”

1. We Do Not Sell Your Personal Information

The CCPA requires us to disclose whether we sell your Personal Information. We do not sell your Personal Information.

2. Your Rights Under the CCPA

The CCPA provides Californians with the following rights:

  • Requests for Information. Under the CCPA, you can request that we disclose how we have collected, used, and shared your Personal Information over the past 12 months, including the categories of Personal Information we collected and our purposes for doing so; the categories of sources for that Information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. Companies that sell Personal Information (we do not) must make additional disclosures.
  • Your Right to Opt Out of Sales. We do not sell Personal Information, so we don’t have an opt out.
  • Your Right to Notification. Under the CCPA, a business like NextGate cannot collect new categories of Personal Information or use them for materially different purposes without first notifying you.
  • Nondiscrimination for Exercising Your CCPA Rights. The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
  • Your Right to Delete Personal Information. oneDID™ users can delete their Personal Information in the oneDID app by deleting the app. You also can request that we delete specific information about you. We honor such requests unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when information is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs, or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
  • Annual Metrics as Required by Regulation § 999.317(g). From the period of ____________, 2020 to _________, 2021, NextGate has not received any valid CCPA right requests from California consumers.]

3. The CCPA Categories of Personal Information We Collect and the Sources

Our Privacy Policy describes the information we collect and its sources. This notice organizes that information around the Personal Information categories set forth in the CCPA.

CCPA Personal Information Category

Sources of this Information

Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)

Information you provide directly or through your interactions with our Offerings or through our partners (as defined in our Privacy Policy)
Vendors that provide information to help us in marketing our Offerings
Information from other customers

Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”)

Information you provide to us directly and inferences we make based on that information

Information from our customers

Commercial information (e.g., information regarding products or services purchased, obtained, or considered)

Information you provide to us directly

Information from our partners and customers

Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Offerings)

Your interactions with our Offerings

Your visits to third party sites that offer our autofill, follow us, as needed for fraud prevention and security purposes.

Your interactions with the services of partners and customers that use our Offerings

Geolocation Data

Information you provide to us directly or through your interactions with our Offerings

Professional or Employment-Related Information

Information you provide to us directly

Information from our customers, partners, or other individuals

Inferences

Information you provide to us directly or through your interactions with our Offerings

Information from our customers and partners

Personal information described in Cal. Civ. Code §1798.80(e) (such as name, address, telephone number, education, employment history)

Information you provide directly or through your interactions with our Offerings

Information from our customers or partners

Audio, electronic, visual or similar information

Information you provide directly or through your interactions with our Offerings, customers, or partners

Biometric Information

Information you provide directly through your interactions with our Offerings

4. The CCPA Categories of Personal Information We Share for a “Business Purpose”

While we do not sell your Personal Information, we may share it to support our own operational purposes in providing our Offerings to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, we may share Personal Information at your direction, such as when you choose to use our Offerings to communicate with other service providers.

  • Auditing Interactions. We may share the types of Personal Information listed in Section 3 with partners, service providers and related companies, in order to audit interactions and transactions.
  • Security Purposes. In order to secure our Offerings, including to detect, prevent, and investigate security incidents or violations of our Terms of Service or applicable laws, we may share the types of Personal Information listed in Section 3 with our partners, service providers, law enforcement, and related companies.
  • Service Improvements. In order to improve our Offerings (such as to identify bugs, repair errors, or ensure that services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of Personal Information listed in Section 3 with our partners, service providers, and related companies.
  • Service Providers and Other Notified Purposes. We may share the types of Personal Information listed in Section 3 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).