California Privacy Policy
Last modified: April 28, 2021
This California Privacy Policy for California residents (“California Privacy Policy”) is provided by FrankSpeech LLC (“FrankSpeech,” “we,” “our,” or “us”), and applies solely to the Personal Information (as defined below) that we collect and use relating to users who reside in California (“you,” “your,” or “user”). This California Privacy Policy supplements and is parallel in scope to our Privacy Policy. Please read the Privacy Policy and Terms of Use carefully before you start to use www.frankspeech.com and all related services (this “Website”). We provide this California Privacy Policy to comply with California privacy laws, including the California User Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.
Definitions Specific to this California Privacy Policy
The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to our Privacy Policy, including the following terms:
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household. Personal Information does not include publicly available information obtained from government records; de-identified or aggregated user information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a user’s Personal Information by the business to another business or a Third-Party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a user’s Personal Information for a business purpose pursuant to a written contract.
“Third-Party” means a person or entity who is not a business that collects Personal Information from users, as defined in the CCPA, and to whom the business discloses a user’s Personal Information for a business purpose pursuant to a written contract.
Overview
We use reasonable security measures to protect your information including industry-standard processes for sharing information with Third-Parties. You should note that this Website may contain links to or content from websites or other online services provided by Third-Parties.
The CCPA requires that we use the term “sell” to include even Personal Information-sharing with business partners for operational services. Accordingly, we use this expanded definition of “sell” throughout our California Privacy Policy. When we disclose that we may “sell” Personal Information, it means that we and you may receive some kind of benefit in return for sharing Personal Information, even if no money changes hands.
When you visit this Website, we may use cookies and other technologies to collect information. These technologies help us personalize experiences, understand news preferences, and learn about the devices used to access this Website. The summary provided below describes all information collected on this Website. Keep in mind that collection includes information you provide to us for our services and passive information regarding your activity on this Website.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we may have collected in the past twelve months, examples of the type of Personal Information in each category, the sources from which each category of Personal Information is collected, the business purpose(s) for which that category of Personal Information is collected, and all types of Third-Parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to Third-Parties for a business purpose. We also sell or share certain Personal Information to Third-Parties.
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Categories of Personal Information |
Examples |
Types of Sources from which this Category of Personal Information Is Collected |
Business Purposes for Collection |
Types of Third-Parties with Whom this Category of Personal Information Is Shared/Sold and/or Disclosed |
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Unique identifiers |
Name, signature, address, telephone email, account name, online identifier, IP address
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- Directly from you through this Website - Business partners
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- Identification for account or profile creation - Security and fraud prevention - Provide user service and assess satisfaction - Personalize user experience - Improve products and services - Improve marketing and user communications - Comply with legal requirements |
Disclosed: - IT Service Providers - Affiliates
Shared/Sold: - Online analytics providers - Marketing partners
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Protected class data |
Characteristics of protected classifications under California or federal law, including: race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status |
- Directly from you through this Website
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- Identification for account or profile creation - Security and fraud prevention
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Disclosed: - IT Service Providers - Affiliates
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Internet activity |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a user’s interaction with an internet website, application, or advertisement |
- Directly from you through this Website
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- Provide user service and assess satisfaction - Personalize user experience - Improve products and services - Improve marketing and user communications - Comply with legal requirements |
Disclosed: - IT Service Providers - Affiliates
Shared/Sold: - Online analytics providers - Marketing partners
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We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
Information Collection
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
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If you would like to request (1) specific pieces or the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of Third-Parties with whom we have shared that Personal Information; and/or (4) the business purposes for collecting, using and sharing that Personal Information, email us at [email protected] and describe your request.
Verification Process
After we receive your request, to ensure the security of the information we store and users’ privacy, we will verify that you are appropriately affiliated with the subject of the request, either as the user or as an authorized agent or guardian of the user. We may ask you to provide a few pieces of information to confirm your identity in our records.
We will only send CCPA verification questions from [email protected]. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our CCPA verification email address listed above, do not respond.
Any information we gather through this process will only be used for user verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.
Non-Discrimination
We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive user requests as permitted by the CCPA.
Deletion of Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
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If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, email us at [email protected] and describe your request.
Authorized Agents
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
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Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
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You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
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We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
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Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.
Personal Information of Minors
We are proud of our online information and we strive to ensure we do not offend people of any age. However, this Website is not intended for children or minors under the age of sixteen years. Accordingly, we do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to us, please contact us at [email protected] and we will delete the information.
Right to Opt-Out
You have the right to request that we do not sell Personal Information that we have collected or opt-out of us sharing your information with Third-Parties.
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If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, email us at [email protected] and describe your request.
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If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
Additional Information
If you would like additional information regarding our California Privacy Policy, please email us at [email protected].
Additional Privacy Rights
California Civil Code Section § 1798.83 permits users of this Website who are California residents to request certain information regarding our disclosure of Personal Information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”
Changes to this Policy
FrankSpeech reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated California Privacy Policy on this Website with the last modified date.