PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: November 1, 2021
This Privacy Notice for California Residents is provided on behalf of Bellum AI, LLC and its affiliates (collectively, “Company,” “we,” “our,” or “us”). Please note the following:
- This Notice applies solely to California residents who are customers of Company or who visit the Company’s physical or online properties (“consumers” or “you”).
- We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
- This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals and used only within the context of such a relationship.
- Where noted in this Notice, the CCPA temporarily exempts from some of its requirements personal information reflecting a written or verbal business-to-business communication (“B2B personal information”).
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope like personal information covered by certain sector-specific privacy laws.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, email address, account name, unique personal identifier, social media handles, online identifier, Internet Protocol address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, telephone number, bank account number, credit card number, debit card number, or any other financial information.Some personal information included in this category may overlap with other categories.
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 (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of real or personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history.
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.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from reservations or other forms you complete or transactions you request.
- Indirectly from you. For example, from observing your actions on the Company’s online properties.
- From other sources. For example, information from social media services, commercially available sources and information from our affiliates or business partners.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, to enable you to book an event, or to participate in features or offers such as market research surveys, studies, tournaments, games, contests, questionnaires, polls, sweepstakes, and user forums. We may also save your information to facilitate your ongoing relationship with us.
- To design, provide, administer, support, personalize, promote, and develop our online properties, tools, products, business, operations, and services (e.g., bookings, newsletters, reports, apps, games, mailings, alerts, notifications requested or agreed by you).
- To create, maintain, customize, and secure your account with us.
- To process and communicate with you regarding your questions, requests and transactions.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your experience on our online properties and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our online properties, third-party sites, and via email or text message.
- To help maintain the functionality, safety, security, and integrity of our online properties, products and services, databases and other technology assets, and business, and to protect against fraud or for risk management purposes.
- For testing, research, analysis, and product development, including to develop and improve our online properties and our products, services, and other offerings.
- To protect our rights and property, and to enforce our policies, procedures and agreements.
- 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, pursuant to your consent, or as otherwise set forth in applicable law.
- As part of a substantial corporate transaction, such as a sale, merger, consolidation, divestiture, restructuring, reorganization, dissolution, or asset sale.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. We share your personal information with the following categories of third parties:
- Service providers.
- Third parties who participate in a substantial corporate transaction, such as a sale, merger, consolidation, divestiture, restructuring, reorganization, dissolution, or asset sale.
- Governmental authorities and other third parties to comply with legal requirements such as a law, regulation, search warrant, subpoena or court order; or in special cases, such as in response to, to prevent or to stop a physical threat, harm, threats to safety, liability, risks, criminality or tortious conduct onto you, us, our users, their property, or defend or assert legal rights.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information of consumers.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information, except for B2B personal information where noted. This section describes your CCPA rights and explains how to exercise those rights, which are subject to our records retention policies and applicable law.
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 past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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, if applicable in the future, 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).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide access and data portability rights for B2B personal information.
Deletion Request Rights
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 (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 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.
We do not provide deletion rights for B2B personal information.
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:
Only you, or someone legally authorized 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. To initiate the process of designating an authorized agent, you may submit a verifiable consumer request using one of the means set forth in the Contact Information section below and specifying your request in detail sufficient to enable us to verify and complete your request.
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, which may include: a valid government-issued identification (including passport and/or driver’s license), together with a utility bill during the last 3 months indicating the same name and details on the identification.
- 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. However, we do consider requests made through your password-protected account (if applicable) sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (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.
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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right under the CCPA to direct us at any time not to sell your personal information in the future (the “right to opt out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to personal information sales may opt out of future sales at any time.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us by contacting us using the information in the Contact Information section below.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by contacting us using the information in the Contact Information section below.
You do not need to create an account with us to exercise your opt-out rights.
You have a right under the CCPA not to receive discriminatory treatment because you exercised any of your CCPA rights. Unless permitted by law, 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 personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Company Services and update this Notice’s effective date. Your continued use of the Company Services following the posting of changes constitutes your acceptance of such changes.
Postal Address: 222 West 44th Street, New York, NY 10036