Copyright © 2023 Olivia Bennett
This Privacy Notice for California Residents supplements the information provided by Olivia Bennett LLC, a Texas LLC (the “Company”), in the Company’s link and applies solely to all visitors, users, and others who reside in the State of California (“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.
Information We Collect
- Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
- Commercial information (such as transaction data);
- Financial data (such as credit card information);
- Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);
- Geolocation data (at an IP-based or city/state/zip level);
- Professional or employment-related information (if volunteered in a job application);
- Education information (if volunteered in a job application);
- Inference data about you drawn from the data in this section (based on user profile information and classes taken);
- Legally protected classifications (such as age and gender);
- Physical characteristics or description (if personal photo is volunteered in a user profile); and
- Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the AWO services, such as additional profile information or user-generated content).
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
The Company obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions via the AWO Platform.
Use of Personal Information
We may use, sell, 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. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our AWO Platform, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- 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 AWO Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our AWO Platform, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our AWO Platform, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our AWO Platform, products, and services.
- 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 the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our AWO Platform users is among the assets transferred.
The Company 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.
Sharing Personal Information
The Company may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). 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. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
- Service providers.
- Data aggregators.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that the Company 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 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.
Deletion Request Rights
You have the right to request that the Company 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, 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.
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 email at https://oliviabennett.wpengine.com
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 also make a verifiable consumer
request on behalf of your minor child.
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.
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 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 forty-five (45) 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. 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, specifically electronic delivery.
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 to direct us to not sell your personal information at any time (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 between 13 and 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.
Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”) Opt-Outs
The Digital Advertising Alliance (“DAA”) and the Network Advertising Initiative (“NAI”) offer tools to provide
consumers with choices as to whether participating third parties can use your information to provide targeted
advertising. To opt out of sharing your information with such participating third parties for targeted advertising,
please use the following tools:
- For Websites: The DAA CCPA Opt Out Tool, available at https://optout.privacyrights.info/?c=1, and the NAI Consumer Opt-Out Tool, available at http://optout.networkadvertising.org/?c=1.
- For Mobile Applications: The DAA CCPA App Opt Out Tool, available at https://www.privacyrights.info/appchoices and the NAI App Opt-Out Tool, available at https://www.networkadvertising.org/mobile-choice.
- The DAA and NAI opt-outs described above are device- and browser-based. Because the information being shared relates to your device ID and/or browser ID, you must opt out on each device and each browser where you want your choice to apply.
- Opt-outs may be stored via cookies. If you clear cookies, your opt-out will no longer be valid and you must opt out again where you want your choices to apply.
- The above choices will not opt you out of the use of previously collected and shared information or all interest-based advertising (such as that conducted on other sites).
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our AWO Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to https://oliviabennett.wpengine.com
Changes to Our Privacy Notice
The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the AWO Platform and update the notice’s effective date. Your continued use of our AWO Platform following the posting of changes constitutes your acceptance of such changes.