Legal

ELECTRIFAI’S POLICY REGARDING THE CALIFORNIA CONSUMER PROTECTION ACT

California Consumer Privacy Act Notice
Effective Date: January 1, 2020

Additional Information for California Consumers

In compliance with the California Consumer Privacy Act of 2018 (“CCPA”), ElectrifAi, LL (“ElectrifAi”) and its affiliates are providing this California Consumer Privacy Act Notice (“CCPA Notice”). Any terms utilized in the CCPA shall have the same meaning as those included in this notice. This CCPA Notice supplements the information in our Privacy Policy and is only applicable to California consumers, as of January 1, 2020.

Categories of Personal Information that We Collect, Disclose, and Sell

As defined by the CCPA, below are the categories of personal information about California consumers that we may collect, sell, and disclose for a business purpose.

Categories of personal information and examples Is this data collected? Is this data disclosed for a business purpose? Is this data sold?

Category: Identifiers

Examples: his or her 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

NO

NO

NO

Category: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80 (e))

Examples: 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

NO

NO

NO

Category: Protected classification characteristics under California or federal law

Examples: race, color, ancestry, national origin, religion

sex (including pregnancy, childbirth, and related medical conditions), age (40 and older), genetic information, marital status, sexual orientation, gender identity and gender expression, military or veteran status

NO

NO

NO

Category: Commercial information

Examples: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

NO

NO

NO

Category: Commercial information

Examples: imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information

Yes

NO

NO

Category: Internet or other similar electronic network activity information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement

NO

NO

NO

Category: Geolocation data

Examples: Device location, physical location or movements

NO

NO

NO

Category: Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information

NO

NO

NO

Category: Professional or employment-related information

Examples: Performance evaluations, current or past job history

NO

NO

NO

Category: Inferences drawn from other personal information

Examples: Profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

NO

NO

NO

Information We Collect When You Visit Our Site

ElectrifAi and the third parties we engage to perform analytics or advertising may use cookies or similar technologies to administer and improve our website www.electrifai.net ("Site"), and the content on it, including to track user movements around the Site to gather usage information and statistics about how our Site is used, to permit users to log in or make purchases, to store user preferences, to customize content, and for marketing and advertising purposes. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine the information we have automatically collected from you with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality, to develop new products and services, and to customize content and advertising to you.

The following are some examples of information we may collect with cookies, log files, Web Beacons, GIFs, pixel tags, server logs, customer relationship management ("CRM") tools or other technologies that gather information automatically when you visit our Site or view online advertisements:

  • Website pages you view
  • IP address
  • Emails from ElectrifAi that you open or forward
  • ElectrifAi offers or links you connect to

Information We May Collect Directly

Some Personal Information may be collected directly from you or an authorized third party:

  • Name
  • Contact information (email address, postal address, phone number)
  • Other information you may voluntarily provide
  • Product Preferences and interests
  • Communication Preferences
  • When you call or exchange emails with us, we may retain the content of the email messages (or hard copy correspondence) as required or permitted by law and our record and information management policies. We also may retain recordings of our phone messages or phone calls with you as by permitted by law.

Information we may collect from other sources ("Third Party")

We may obtain information about you from third party sources, such as the companies we work with to provide service to you (i.e. our service partners), affiliates and other companies that we acquire or merge with, data aggregators or public databases. Here are examples of this kind of Third Party Information:

  • Name
  • Age
  • Postal Address
  • Phone Number
  • Other information which may help us determine your risk of identity theft such as online behavior, purchase behavior, interests and other consumer and market research data

How We Use and Share Your Information

This summary tells you how we use your information, if we share it and why. It also explains how you can make decisions about these actions and how we will respond to those requests. We will share your personal information with third parties only in the ways that are described in this Privacy Policy, or otherwise where we have your consent. We do not sell your personal information to third parties. When we share your Personal Information with third parties as described below, we put in place contracts with them that include confidentiality restrictions on their use of your information and that require them to notify us if your Personal Information is lost, stolen or otherwise wrongly disclosed.

Why do we USE your information? Do we SHARE this information with others? What information is shared? Can you limit this sharing?

To understand Site demographics and use of the Internet

Yes. We share with our affiliates and third-party service providers to help improve our products, service offerings, Site, and technology

General information

You may block cookies through your browser settings, which prevents us from collecting certain information about your use of our Site and our Services. We may still collect information about your use of our Services, such as when you log in, and analyze this information to help understand the use of our Site.

In the course of providing Services you request, verifying your identity, notifying you of new features, Services, or changes in our business or to process, and fulfilling or billing your orders or requests.

Yes, with the following:

  • users registered under your account
  • our affiliates
  • third party service providers
  • Government agencies and law enforcement (in helping address identity theft)
  • consumer reporting agencies

General information; Personal Information

No. This is necessary to provide the Services, including updates about features and functionalities of the products and services to which you subscribe. The information requested may differ depending on the Service(s) you select. This use of your information is separate and distinct from marketing uses, which you may opt-out of, and which are discussed below.

When we, or our affiliates, send you marketing material about services, promotions or other material which may be of interest to you, through e-mail, interactive voice response telephone technology, direct mail or other means.

Yes, with our affiliates and to third party service providers who are under contract with us to provide our direct mail or other marketing efforts

General information; Personal Information such as Name, Address, Email Address, or Phone Number; Third Party Information

Yes, by opting out of communications in your preferences or by contacting us at privacyinfo@electrifai.net

Behavioral or Interest-based Advertising (to send you focused advertising)

Yes, with service providers and network advertisers (as described under "Behavioral or Interest-based Advertising")

General information elements of your Personal Information such as Name, Address, Email Address, and Phone Number;

Third Party Information

Yes, you may exercise your options to not receive behavioral advertising, including targeted ads about ElectrifAi products on certain third party sites, as described in “Tracking and Interest Based Advertising” below.

Exercise your choice to limit use of your information by ElectrifAi for behavioral advertising purposes here privacyinfo@electrifai.net.

To investigate misconduct or a crime, to comply with the law, or when we believe it is necessary to protect our rights, property or safety or that of others

Yes, with law enforcement, attorneys, officers of the court, arbitrators, mediators and others involved in any judicial proceeding, court order, similar legal process or the like

General information; Personal Information; Third Party Information

No

In connection with our sale, purchase, merger or reorganization

Yes, with the acquiring, purchasing, or other applicable entity, including, without limitation, legal and financial advisors and other persons or entities as appropriate

General information; Personal Information; and Third Party Information

No

Marketing

If you provide us with your email address or mailing address, you may receive marketing messages and materials from us or our affiliates. You have choices on what communications you want to receive from us. Marketing materials for our Services may also be included in messages you receive from our partners (which may include your employer if they offer our services as part of their employee benefits) or service providers that offer our services as part of a special offer. If you choose not to receive marketing communications that we send, we will honor your request. However, we will continue to communicate with you as needed to provide the Services, respond to your inquiries or otherwise relay service-related messages. You may still receive information about our Services through other parties using their own mailing lists.

Your Rights and Choices

Under the CCPA, if you are a California resident you have the following rights:

  1. The right to know what personal information has been collected about you over the past 12 months. The types of personal information you have a right to know include: the categories of personal information we have about you and their sources, the business or commercial purposes for collecting or selling your personal information, the categories of third parties whom we have shared your personal information with and what exactly has been shared in relation to your personal information. Requests for this information can be received twice a year, at no charge to you.
  2. The right to have personal information deleted. However, due to legal limitations we might not be able to and/or be required to delete certain personal information. Any deletions on our part will be informed to you.
  3. The right to prohibit the sale of your personal information to third parties in exchange for gain to us, which is also known as the “Do Not Sell” right. This “Do Not Sell” provision under the CCPA can be exercised by sending us an email to legal@electrifai.net with the subject line “Data Privacy Rights” or calling us at : +1 (646) 520-4320 with contact information, so we may reach you. Personal information from California residents who we know are younger than 16 years old is not sold unless we have opt-in consent.
  4. The right not to be discriminated if you decide to exercise any of your rights described under this CCPA Notice. Any products and/or services we sell will not be charged different rates if you decide to exercise your rights specified hereunder. Further, we do not provide financial incentives and/or different rates for either selling or sharing your personal information.
  5. The right to request what personal information we house about you and to delete said data. Requests for this information can be done by sending us an email to legal@electrifai.net with the subject line “Data Privacy Rights” or calling us at : +1 (646) 520-4320 with contact information, so we may reach you. Your identity will need to be verified in order for us to release this information to you. If we cannot verify your identity upon your request for your personal information or if we feel this will pose a security issue, we will be able to disclose only general information about the types of personal information we have in relation to you. Requests for deletion of your personal information will be honored only subject to us being able to verify your identity. Note that there are certain instances where we will not be able to delete your information due to a legal basis which may require us or allow us to retain your personal information.

Authorized Agents

California consumers can select an authorized agent to exercise their rights on their behalf under the CCPA. Requests received by authorized agents will be honored upon proof of identity, evidence of written authorization to act on your behalf and provided they are registered with the Attorney General.

Requests made on behalf of a “Household”

California consumer can make requests on behalf of their household. These requests can be done by sending us an email to legal@electrifai.net with the subject line “Data Privacy Rights” or calling us at : +1 (646) 520-4320 with contact information, so we may reach you. Requests will be honored once we have been able to verify everyone in your household, provided it does not pose a security risk for anyone in that household.

California Privacy Rights under “Shine the Light” Law

Under this law, California residents are entitled to request what third parties we have disclosed their personal information to in the past 12 months for their direct marketing purposes.

These “Shine the Light” or “Eraser” law requests can be done by sending us an email to legal@electrifai.net with the subject line “Data Privacy Rights” or calling us at : +1 (646) 520-4320 with contact information, so we may reach you.

Changes

ElectrifAi, LLC reserves the right to revise this CCPA Notice at any time, at our sole discretion. Any and all changes will either be shared by email sent to you and/or posted on our Site.

Contact Us

If you have any questions about this CCPA Notice, or wish to exercise your rights under California law, please contact us at legal@electrifai.net with the subject line “Data Privacy Rights”.

You can also reach us at: Attention: ElectrifAi, LLC, Attention: Business & Legal Affairs Department, 10 Exchange Place, 11th Floor, Jersey City, New Jersey 07302.

Phone: +1 (646) 520-4320

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