Shindig Privacy Notice for California Residents
Effective: October 1, 2020
Shindig, Inc. (“Shindig,” “we,” “Company”, “us” or “our”) provides and makes available this web site and online application (the “Web Site”) through which Shindig provides and makes available a platform whereby any registered member of the Web Site (“you” or “Member”) may participate in online events, collaborative work, game play, socialization and other offerings (the “Platform”)
Information Shindig May 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:
- 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|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).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|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, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||YES|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment related information||Current or past job history or performance evaluations.||YES|
|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||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||NO|
We obtain 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 or from communications with you such as when you contact Shindig (whether in person, by mail, by phone, online, via electronic communication or by any other means).
- Indirectly from you. For example, from observing your actions on our Website or our Apps.
- From others. For example, from third party service providers. If you make an electronic payment directly to Shindig, or through a web site or an app, Shindig may receive personal information about you from third parties such as payment services providers, for the purposes of that payment.
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 instance, if you contact Shindig by e-mail, Shindig will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Shindig Services, Shindig will use your Personal Data to provide you with access to such services and to monitor your use of such services
- To perform services such as customer service, payment processing, financing and advertising, marketing or analytic services.
- To contact you in the future to tell you about products and services Shindig believe will be of interest to you.
- To help Shindig improve the content and functionality of the Web Site, to better understand Shindig's users and to improve the Shindig Services
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- 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 otherwise use as reasonably necessary and proportionate to achieve our operational or notified purpose for collecting personal information and as compatible with the context in which we collected the information.
- To perform services on behalf of a CCPA-covered business or its service provider, such as customer service, order fulfillment, payment processing, financing and advertising, marketing, or analytic services.
- To Audit the interaction with you.
- To detect or prevent security incidents or other illegal activity.
If Shindig intends on using any Personal Data in any manner that is not consistent with this Privacy Notice, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
Sharing Personal Information
Shindig is not in the business of selling your information. Shindig considers this information to be a vital part of Shindig's relationship with you. There are, however, certain circumstances in which Shindig may share your Personal Data with certain third parties without further notice to you, as necessary to fulfill the business purposes for which the Personal Data was collected, or as otherwise set forth below:
Service Providers: We may share certain Personal Data and other information that we receive with vendors and service providers as necessary to fulfill the purposes for which you provided such information in connection with the Shindig Services. For example, we may provide:
- Contact information such as your email address to email service providers to send out newsletters and other content or materials related to the Shindig Services; and/or
- Payment method information to payment processors we use for any transactions you authorize in relation to the Shindig Services.
Business Transfers: As Shindig develops Shindig's business, Shindig might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: Shindig, like many businesses, sometimes hires other companies to perform certain business-related functions. When Shindig employs another company to perform a necessary business-related function on our behalf, Shindig only provides them with the information that they need to perform their specific function.
Legal Requirements: Shindig may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Shindig, (iii) act in urgent circumstances to protect the personal safety of users of the Shindig Services or the public, or (iv) protect against legal liability.
The Shindig Services may allow you to share information, including Personal Data, with third-party services and social networking websites, such as Twitter, Facebook, YouTube and LinkedIn. Depending on the privacy settings you have established with the applicable social media platform, and whether you use such platform in connection with the Shindig Services, you may encounter targeted advertisements based on your browsing behavior before and after you use the Shindig Services. We do not share your Personal Data with these social media providers unless you direct the Shindig Services to do so. Their use of the information will be governed by their privacy policies, and you may be able to modify your privacy settings with these entities. Please consult these third parties’ privacy policies before using their platforms to make sure you are comfortable with the level of sharing.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- Internet cookie data recipients like Google Analytics
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold any information.
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 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), 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.
We do not provide these 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, 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, such as future field campaigns or product safety issues.
- 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 these 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:
- Calling us: 646 896 1747.
- Emailing us at firstname.lastname@example.org.
- Visiting https://shindig.com/data-subject-request-form/.
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.
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:
- Your name
- Additional information depending upon the type of request and the sensitivity of the information.
- 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 will consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account, provided the functionality is available.
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.
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, we will inform you of the reason and extension period in writing.
If you have an account with us, we may deliver our written response to that account, provided that such functionality is available. If you do not have an account with us, or the functionality is not available for your account 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.
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
While we do not sell the personal information, 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 will 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 visiting our web-site
Do Not Sell My Personal Information
We will only use personal information provided in an opt-out request to review and comply with the request. 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you services.
- Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level of services.
- Suggest that you may receive a different price or rate for services or a different level of quality of services.
Other California Privacy Rights
Before sharing personal information of California residents with third parties for direct marketing purposes we will obtain opt-in consent or a cost free method to opt out.
Changes to Our Privacy Notice
We reserve 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 Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Shindig collects and uses your 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:
Phone: 646 896 1747