CCPA PRIVACY NOTICE
[Last Modified: December 27, 2022]
APPLICABILITY: The California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), any other California privacy laws, and this CCPA Notice apply to visitors, employees, users, applicants for employment, and independent contractors, and others who are California residents (“consumers” or “you”). Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our service or in order to provide our services, or employee and business-to-business Personal Information.
PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:
(A) CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We collect Personal Information which 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, all as detailed in the table below.
Personal Information further includes Sensitive Personal Information (“SPI”) as detailed in the table below.
Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) 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.
We have collected the following categories of personal information within the last twelve (12) months:
Category A: Identifiers.
Data Collected: A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Data Collected: A name, telephone number.
Category G: Geolocation Data.
Data Collected: approximate geolocation
(B) CATEGORIES OF SOURCES OF PERSONAL INFORMATION
Indirectly from activity on our website and app: when you use our website, we will collect your Identifiers.
Directly from our users: For example, when the users contact us, when use our App's services and provide us their information and the Contac's information.
From third-parties: For example, from vendors who assist us in performing services for users, internet service providers, data analytics providers and data brokers.
Publicly accessible sources.
(C) USE OF PERSONAL INFORMATION
We 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.
(D) DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
We may disclose your Personal Information to a contractor or service provider for a business purpose. 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, we further restrict the contractor and service provider from selling or sharing you Personal Information. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose
We Share Personal Information of Category A, Category B and Category G we collect from our users and Contacts with our affiliate company: Lusha Systems Ltd., for a business purpose that includes a verity of services provided to us by Lusha Systems Ltd.: debugging, security, fraud prevention, enrichment, development, support.
We Share Personal Information of Category A, Category B and Category G we collect from our users and Contacts with our service providers which provide us with the following services: Cloud computing, storage, operations,
We may disclose all of the Personal Information we collect from you with Government Entities/Law Enforcement if we requested to do so.
We may share Personal Information of Category B which we collect from Caller ID App end users with other users of our Caller ID App
(E) SALE OR SHARE OF PERSONAL INFORMATION
The definition of “sale” and “share” under the CCPA is broad, under this definition the Company has sold Personal Information in the last twelve (12) months the Personal Information listed in Category B. We share the contacts’ information, the name and phone number as provided by our App users, with Lusha System Ltd. which provides us with the enrichment data, so that we can add professional information such as title, job and position to our users’ contact list. This is considered a sale under the CCPA.
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.
(F) CHILDREN UNDER AGE 16
We do not knowingly collect information from children under the age of 16.
(G) DATA RETENTION
The retention periods are determined according to the following criteria:
For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM
(H) YOUR RIGHTS UNDER THE CCPA
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed below and the in the Data Subject Request Form available here.
Access Rights. You may access and request a copy of the specific personal information collected by us about you.
Deletion Rights. The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. You may exercise this right directly from our App settings by clicking “Delete Account” and then uninstall the App.
Correct Inaccurate Information. The right to correct inaccurate Personal Information that a business maintains about a consumer which can be done through the App settings.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising. You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.”
Opt-out from selling. the right to opt-out of the sale or sharing of Personal Information by the business, as further detailed below.
Limit the Use or Disclosure of SPI. Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business.
Non-Discrimination. The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information. You may freely exercise your privacy rights without fear of being denied the Services.
Data Portability. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
(I) HOW CAN YOU EXERCISE THE RIGHTS?
You may opt out of Sharing or Selling Personal Information through our opt-out webpage or within the App settings, by opting out from enrichment data services.
Otherwise please submit a request to exercise your rights using the Data Subject Request Form available here and send the form to email@example.com
The Instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed in the Data Subject Request Form available here.
(J) AUTHORIZED AGENTS
“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures
a. When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
Provide the authorized agent signed permission to do so or power of attorney.
Verify their own identity directly with the business.
Directly confirm with the business that they provided the authorized agent permission to submit the request.
b. A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
(K) NOTICE OF FINANCIAL INCENTIVE
We do not offer financial incentives to consumers for providing Personal Information.
L.S. Mobile Apps Holdings Ltd.,
132 Derech Menachem Begin
Tel Aviv, Israel, 6701101
PART III: OTHER CALIFORNIA OBLIGATIONS
Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
California’s “Shine the Light” law (Civil Code Section § 1798.83): permits employees 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 us the Data Subject Request Form available here.