Legal – CCPA Privacy Notice

A.     Introduction

This CCPA Privacy Notice governs the manner in which we process information collected from users
who reside in the State of California (“Consumers” as defined under the CCPA, and will be referred to herein as “you”). Any terms defined in the CCPA have the same meaning when used in this Notice. Furthermore, this Notice is an integral part of our Privacy Policy and thus,  definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

 

 

B. Categories Of Personal Information

“Personal Information” that is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device as detailed in the table below.

Please see below a table detailing the categories of Personal Information that we collect (and have collected within the last 12 months):

 

Category

Examples of Personal Information

Collected

Retention Period
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 The information will be retained for the time necessary to fulfill the purpose for which it was collected. For example, we will retain your name and email provided as part of any correspondence between you and Wib in accordance with the applicable statute of limitations.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, physical characteristics or description, address, telephone number, passport 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 – without any Sensitive Information as detailed below. In accordance with the applicable statute of limitations (e.g., at least seven years).
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 N/A
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No N/A
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. No N/A
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes Cookies and IP data may be kept as long as you are a user of our website, or until you have withdrawn your consent.
Note that online identification data collected through third parties may be kept for different periods in accordance with such third party’s policies (e.g., Google Analytic data may be kept for up to 14 months).
G. Geolocation data. Physical location or movements. No N/A
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No N/A
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes At least until the end of the recruitment process, and further in accordance with the applicable statute of limitations (e.g., up to seven years following the recruitment process).
Hired employee’s data will be kept for longer periods in accordance with labor law and other records keeping obligations.
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 N/A
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No N/A
L. Sensitive Personal Information Any information about a person’s health, sexual orientation, financial status and credit rating, social security number and other similar governmental identifiers, genetic, ethnic or racial data, precise location, biometric information or the contents of a any mail, email, and text messages unless we were the intended recipient of the communication. No N/A

 

 

C. Disclosures Of Personal Information For A Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

  • Category A: Identifiers;
  •  Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) without any Sensitive Information;
  • Category I: Professional or employment-related information.

We disclose your Personal Information for a business purpose to the following categories of third parties: service providers (e.g., marketing, analytic, etc.) and business partners.

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.

 

 

D. California Consumer Rights

California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

Requests for Copy, Deletion, Correction and Right to Know – Subject to certain exceptions, California consumers have the right to make a request pertaining to either Accessing, Copying, Correcting or Deleting their data. As those rights are not absolute, we wouldn’t always be required to comply with your request. However, we will always address your inquiry and endeavor to explain the reasoning for our decision in case your request will be denied. Please see “Submitting Requests” for instructions on how to exercise your rights.

Right to Limit Use and Disclosure of Sensitive Personal Information – in general, the regulation provides any consumer to order a business to limit the use and sharing of its Sensitive Personal Information. However, since we are not using or sharing any sensitive information of our website visitors, that right is not relevant in our case.

Submitting Requests. You can exercise your rights by emailing us at dpo@wib.com, or the designated DSR form in our website. Once you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information and use identity verification services to assist us. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty. We will make every reasonable effort to respond to you within 45 days after receiving a verified request. If we cannot meet this timescale, we will respond as soon as possible over the next 45-day period.

 

 

E. Sale Of Personal Information

In the preceding twelve (12) months, we have not sold Personal Information

We offer all consumers the same ability to opt-out of the sale of their Personal Information that is available to California residents under the CCPA. Based on the CCPA’s broad definition of “sale,” certain data collected on our website by third parties for purposes of interest-based advertising and social media tools may be a “sale” under the CCPA. You may opt out by clicking the “Do Not Sell” option in the footer below.

 

 

F. Sensitive Personal Information, Profiling And Automated Decision Making

We are not using nor sharing any Sensitive Personal Information. Further, as part of the services on the website we do not perform any Profiling of our website visitors, or using any Automated Decision-Making processes with respect to them.

As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Updated” heading located at the top of this Privacy Policy.