PRIVACY POLICY

Digilant is an omnichannel digital media partner built to take advertisers from now to next. Part of ispDigital, Digilant is made up of 100+ data-driven media minds and advertising technologists. Our purpose-built services (hereafter, the “Services”) extend beyond our Boston headquarters with client support and media strategy professionals deeply rooted in New York, Chicago, Denver, Los Angeles, San Francisco, Kansas City, Washington D.C., Dallas, and Atlanta. By providing these Services, Digilant helps advertisers connect their digital advertising spend to growth.

 

Quick Links

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review, we have divided up the document into the following sections:

 

Contact Information

For any questions about this privacy policy or Digilant’s activities, please contact us at privacy@digilant.com or 2 Oliver Street, Suite #901 Boston, MA 02109 USA.

 


Privacy Policy

What’s explained in this Privacy Policy?

Digilant recognizes that when you choose to provide us with personal information about yourself, you trust us to treat it responsibly.

This Privacy Policy explains the types of personal information that Digilant collects about you, how we use, share, and protect this personal information, and the choices you can make about how we use and share this personal information. This Privacy Policy governs personal information collected by any means, including, but not limited to, websites, mobile applications, and other online services that refer or link to this Privacy Policy, as well as information collected by other business functions of Digilant, such as when you speak with a customer service representative (collectively, the “Services”).

It is important that you read this Privacy Policy carefully, because anytime you use our Services you consent to the practices we describe in this Privacy Policy.

What type of data does Digilant collect?

Digilant may collect the following data:

  • IP address
  • The identifier of mobile advertising assigned by the operating systems (Apple and/or Android) to each device, and made available to advertising providers to measure this advertising in mobile apps (Apple’s IDFA or Google’s AAID).
  • Information related to the interactions of users with advertising campaigns managed through the Services and/or Digilant technology.
  • You may provide us information directly.
  • Digilant may collection additional information about you in accordance with applicable law. 

Additional information collected is anonymous and does not allow us to identify specific individuals (for example, browser type, operating system, Internet access provider, browser language, or IP address provider).

Information you provide us directly

We collect information directly from you when you choose to register for our services or otherwise provide information directly to us.  The following are examples of information you may provide us directly:

  • Name.
  • E-mail address, physical address and/or zip code, and phone number.
  • Other information about you, your company or others (such as media and marketing goals).

You can choose not to provide us with certain types of information, but doing so may affect your ability to use some of the Services.

Information we collect when you use our services

We collect information about your computer or device and your online activity, including through the use of standard Internet technologies, such as cookies, web beacons, and local stored objects. The following are examples of the types of information that we may collect:

  • Your browser type and operating system.
  • IP address and/or device ID.
  • Your browsing behavior on our services, such as the amount of time spent viewing our online services, and the links you click within our online Services.
  • Websites you visit before or after our websites.
  • Digilant e-mails you open and/or forward.

Depending on your device settings, location information, such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers.

Information is collected through third-party providers, through the use of web pages and mobile applications. Additionally, the location data generated by the use of mobile devices that capture certain apps may be obtained. Information from publishers and/or mobile providers that provide data associating identifiers (cookies or mobile advertising ID) with information of interest to certain categories may also be obtained for advertising use.

What is the data used for?

Digilant uses collected information to provide its Services, to measure and analyze the efficiency of advertising campaigns, and to optimize advertising campaigns executed on behalf of its clients.

This information is also used to measure and personalize the advertising for each browsing session. This allows users to access more appropriate content, more adapted to categories of interests that can make them more relevant. Among others, this type of treatment prevents users from seeing the same advertisement repeatedly.

Digilant can make use of this information in order to serve advertising based on the location of a device if we have the location data.

We may also use the information we collect about you:

  • To provide you with services or other materials you request.
  • To communicate with you about our Services.
  • To protect the security and integrity of our Services.
  • To enforce our legal rights.
  • Otherwise with your consent.

With whom do we share the data?

  • Collected data may be shared with clients or partners. Our customers can access the services and/or our platform to access the data we collect, for the same purposes as explained above.
  • There may be instances when we disclose your information to other parties:
    • To comply with the law or respond to legal process or a request for cooperation by a government entity.
    • To prevent fraud or verify and enforce compliance with the policies governing our services.
    • Where permitted by law, to protect the rights, property, or safety of Digilant, or any of our respective affiliates, business partners, customers or employees.
  • We may disclose your information to a third party in the event we sell or transfer all or a portion of a business or our assets to a third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.  In certain jurisdictions, consent is required for this sharing of information.  We will collect your consent when required by applicable law.
  • In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.
  • We also may share data in a manner that does not identify you (for example, information that has been aggregated with other records) for general business purposes.  For example, we may disclose the number of visitors to our websites or other Services.

International Transfer of Data

Digilant and its service providers may collect, transfer, store and process your information outside of your country of residence, including to the United States.  Please note that other countries’ data protection and other laws may not be as comprehensive as those in your country.  In accordance with applicable law, we implement measures such as standard data protection clauses to ensure that any transferred personal information remains protected and secure. 

Collection of Information from Children

We do not knowingly collect personal information online from children as defined by local law.  If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.

Information Security and Retention

We have in place various procedures to safeguard your information, including technical, administrative and physical procedures intended to keep your information secure.  However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

In addition, we take steps to retain personal information about you only for so long as is necessary for the purpose for which it was collected, as required under contract, or as required by or permissible under applicable law.

Residents of any European Union Member State

The legal bases for our processing activities are as follows:

  • For our legitimate business purposes, including:
    • to provide you with services, products, or other materials you request (for example, completing your registration for a loyalty program and sending you product samples) and to customize your experience with our Services;
    • to manage and improve your shopping experiences and our products, Services and offerings, including analyzing the use of our products and services, and determining the effectiveness of our advertising; and
    • to protect the security and integrity of our Services.
  • To perform our contract(s) with you, including processing your purchases and transactions,
  • To meet our legal obligations, for example:
    • for audit and reporting purposes;
    • to perform accounting and administrative tasks;
    • to respond to requests for information by competent public bodies and judicial authorities; and
    • to enforce our legal rights and to enforce or manage legal claims.
  • On the basis of your consent:
    • to send you direct marketing messages about our products, services, and promotions; and
    • to deliver targeted advertisements to you, both on and off the Services, including by using cookies and similar technologies, as explained below.

You can withdraw your consent at any time by contacting us.  If you withdraw certain consents, we may no longer be able to offer related services.

  • E-Mail: If you wish to unsubscribe or opt out of receiving direct marking from Digilant b via email, you may follow the instructions contained in any such message.
  • Other:  If you no longer wish to continue receiving other commercial communications from Digilant, you may follow the instructions or use the contact information contained in any such message, or by changing the privacy settings in your browser (for example, with respect to cookies).   

You may lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes applicable law.

Our Services may use web analytics services, such as Google Analytics, which are provided by Google, Inc. and other third party providers. These services use “cookies” to help analyze how visitors use online services. The information generated by the cookies about your use of the online services (including your IP address) will be transmitted to and stored by these providers, including outside the EU in third countries such as the United States which might not have data protection and other laws that are as comprehensive as those in your country.

If your IP address is not truncated through IP-anonymization, then the full IP address may be transferred to third party providers’ non-EU servers. These providers may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.   You may refuse the use of cookies as described elsewhere in this policy, and some providers offer you the ability to prevent the collection and processing of data generated by cookies and related to your use of the website (including your IP address) by downloading and installing a Browser-Plugin.

You can exercise your rights by directing a written communication to the postal addresses indicated above or to the email address privacy@digilant.com indicating in the subject “Data Protection Rights”.

In addition, you can revoke your consent at any time, for which the different ways that we have indicated, in addition to being able to use the alternative of sending us an email to privacy@digilant.com.

What means do you have to exclude yourself or unsubscribe from web or mobile data collection and use?

  • (A) Opposition to treatment or “opt-out”

Users can choose to opt-out of Digilant’s tracking and digital advertising at any time.

To voluntarily unsubscribe in connection with this browser and device, visit Cookie Settings.

It must be taken into account that, by voluntarily excluding itself, Digilant will place an exclusion cookie on the user’s computer, which in turn will inform Digilant that it should not continue to serve personalized digital advertising information or install cookies.

The opt-out or opposition to the processing of data for advertising or behavioral purposes does not imply that other data cannot be processed to carry out measurements and analysis.

  • (B) Download in browser

Cookies are placed specifically in the browser of each device, so it is necessary to voluntarily unsubscribe from all devices used to exclude themselves completely. It must be taken into account that, if cookies are deleted or blocked, if another computer or browser is used, or if the browser is updated on a device, it will be necessary to voluntarily unsubscribe.

  • (C) Download in mobile device

Most devices include an advertising identifier that allows advertisers to track and identify the interests of consumers. They also offer the possibility of voluntarily withdrawing:

  • For iOS: Each iOS device includes an advertising identifier (IDFA) with two key features:
    • Users can reset the identifier at any time.
    • Users can voluntarily unsubscribe by activating the limitation of ad tracking (Limit Ad Tracking or LAT).
  • For Android: Each Android device includes an advertising identifier (AAID). To voluntarily unsubscribe or change the configuration, you must follow these steps:
    • If you use Android 2.3 or higher, select “Google Settings” in the folder of your applications.
    • Select “Ads.”
    • Select “Reset your advertising ID” to generate a new identifier and delete any previously stored data.
    • Select “Disable interest-based ads.”

If you prefer, you can view and modify your cookie preferences by visiting Cookie Settings.

Can this Policy change? 

The Privacy Policy may change in the future, e.g. for regulatory changes, for changes in Services, etc. If the changes affect the way we treat your personal data,, so you can know how they affect you and decide if you want to accept them or not.

The last update of this policy was made on September 22, 2020.

 


CCPA Privacy Policy

Digilant California Privacy Notice

Effective Date: September 20, 2020

This notice reflects our good faith understanding of the law and our data practices as of the date posted (set forth above), but the CCPA’s implementing regulations recently became final and there remain differing interpretations of the law.  Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices. 

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to Digilant’s (“Company“us” “we” “our”) other privacy policies or notices.  In the event of a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.

This Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA for the twelve months preceding the Effective Date.  This Notice also covers rights California Consumers have under the CCPA 

Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. However, our Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department here. Publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available at Title 1.81.5 of the California Civil Code, Sections 1798.100 – .199 for your review, and in some places in this Notice we cite to specific CCPA sections for your reference.  Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.  

You can click on the following links to navigate to the different sections in this Notice.

Table of Contents

  1. PI WE COLLECT
    A. Sources of PI
    B. Use of PI
  2. SHARING OF PI
  3. CALIFORNIA PRIVACY RIGHTS
    A. The Right to Know
    1. Categories 
    2. Specific Pieces
    B. Do Not Sell
    C. Delete
    D. Non-Discrimination and Financial Incentive Programs
    E. Authorized Agents
    F. Limitation of Rights
  4. ADDITIONAL CALIFORNIA NOTICES
    A. Third Party Marketing and Your California Privacy Rights
    B. Online Privacy Practices 
    Tracking and Targeting
    California Minors
  5. CONTACT US

 

1. PI WE COLLECT

Based on our 2020 data practices, we give you notice that we collect the following types of PI about California Consumers, and use and share it as set forth below.  This notice will be updated annually, and our current privacy notices at the point of collection, and general privacy policies, may reflect more current practices.

CATEGORY OF PI

CATEGORY OF RECIPIENTS

1. Identifiers
(as defined in CCPA §1798.140(o)(1)(A))
This may include but is not limited to: 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.
2. Customer Account Details / Commercial Information
(as defined in CCPA §1798.140(o)(1)(D))
This may include, but is not limited to: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
3. Professional or Employment Information
(as defined in CCPA §1798.140(o)(1)(I))
This may include, but is not limited to: professional, educational, or employment-related information.
4. Inferences from PI Collected
(as defined in CCPA §1798.140(o)(1)(K))
This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

The chart above reflects that categories of PI required by the CCPA.  There may be additional information that we collect that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI.  We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.

Return to Navigation

(A) Sources of PI

We may collect your PI directly from you or from service providers, vendors and suppliers, or other individuals and businesses.  

Return to Navigation

(B) Use of PI

Generally, we collect, retain, use, and share your PI to provide you services and as otherwise related to the operation of our business. For more detail on our disclosures and sale of PI, see the next section Sharing of PI.

We may collect, use and share the PI we collect for one or more of the following business purposes: 

  • Managing Interactions and Transactions (§1798.140(d)(1))

 Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the consumer or other parties at the consumer’s request, and to assignees as part of a merger or asset sale (“Other Business Purposes”). 

Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. 

 We do not believe that in 2019 or 2020 we “sold” PI.  For more information on your do not sell rights, see the Do Not Sell subsection of the California Privacy Rights section of this Privacy Notice at Section 3.B below.

In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.   

Return to Navigation

 

2. SHARING OF PI

We may share PI with our service providers, other vendors, and/or affiliates, including without limitation as follows: 

CATEGORY OF PI

CATEGORY OF RECIPIENTS

1. Identifiers
(as defined in CCPA §1798.140(o)(1)(A))
Business Purpose Disclosure: N/A
Sale: Not Sold
2. Personal Records
(as defined in CCPA §1798.140(o)(1)(B))
Business Purpose Disclosure: N/A
Sale: Not Sold
3. Personal Characteristics or Traits
(as defined in CCPA §1798.140(o)(1)(C))
Business Purpose Disclosure: N/A
Sale: Not Sold
4. Customer Account Details / Commercial Information
(as defined in CCPA §1798.140(o)(1)(D))
Business Purpose Disclosure: N/A
Sale: Not Sold
5. Biometric Information
(as defined in CCPA §1798.140(o)(1)(E))
Business Purpose Disclosure: N/A
Sale: Not Sold
6. Internet Usage Information
(as defined in CCPA §1798.140(o)(1)(F))
Business Purpose Disclosure: N/A
Sale: Not Sold
7. Geolocation Data
(as defined in CCPA §1798.140(o)(1)(G))
Business Purpose Disclosure: N/A
Sale: Not Sold
8. Sensory Data
(as defined in CCPA §1798.140(o)(1)(H))
Business Purpose Disclosure: N/A
Sale: Not Sold
9. Professional or Employment Information
(as defined in CCPA §1798.140(o)(1)(I))
Business Purpose Disclosure: N/A
Sale: Not Sold
10. Non-public Education Records
(as defined in CCPA §1798.140(o)(1)(J))
Business Purpose Disclosure: N/A
Sale: Not Sold
11. Inferences from PI Collected
(as defined in CCPA §1798.140(o)(1)(K))
Business Purpose Disclosure: N/A
Sale: Not Sold

We do not believe that in 2019 or 2020 we “sold” PI.  For more information on your do not sell rights, see the Do Not Sell subsection of the California Privacy Rights section of this Privacy Notice at Section 3.B below.  

Return to Navigation

 

3. CALIFORNIA PRIVACY RIGHTS

The CCPA is a new law and there remain differing interpretations of it and the regulations that implement it.  Accordingly, we may from time-to-time update information in our notices regarding our data practices and your rights, modify our methods for you to make and for us to respond to your requests, and/or supplement our response(s) to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices. 

We provide California Consumers the privacy rights described in this section.  You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations.  As permitted by the CCPA, any request you submit to us is subject to an identification [and residency verification] process (“Verifiable Consumer Request”).  We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Please follow the instructions at our Consumer Rights Request page here and respond to any follow up inquires we may make.

Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID).  As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response.  You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests.  We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome.  If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision.  You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Your California Consumer privacy rights are as follows:

(A) The Right to Know

1. Categories

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties to whom we have shared your PI.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months and, for each, the categories of recipients, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months and, for each, the categories of recipients, or that no sale occurred.  

To make a request, click here.

For all requests, we will ask for your first and last name, as well as your email address to verify your identity. If we are unable to find you in our database or records, we will notify you.

For your specific pieces of information, as required by the CCPA, we will apply the heightened verification standards set forth in subsection (ii) below. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

2. Specific Pieces

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.  To make a request, click here

For all requests, we will ask for your first and last name, as well as your email address to verify your identity. If we are unable to find you in our database or records, we will notify you.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

(B) Do Not Sell

There may be cookies and other tracking technologies associated with our online services that may provide data, which may be treated as PI under the CCPA, to other parties that may use it for their own purposes, which in turn may provide that data to other parties for their own purposes. While there is not yet a consensus, we do not believe that data practices of third-party cookies and tracking devices associated with our online services constitute a sale of PI by us and therefore we do not currently treat these activities as a “sale.” Currently, a do not sale request to us will not affect these third-party activities. However, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices.  In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available at https://www.ghostery.com/.  You can also learn more about how to exercise certain choices regarding cookies and interest-based advertising at http://www.aboutads.info/choices/,  http://www.aboutads.info/appchoices, and http://www.networkadvertising.org/choices/

For easy access, here are links on how to manage cookies from some of the more popular browsers:

We do not represent that these third-party tools, programs or statements are complete or accurate. Clearing cookies or changing settings may affect your choices and you may have to opt-out separately via each browser and other device you use. Cookie-enabled opt-outs signals may no longer be effective if you delete, block or clear cookies.  We are not responsible for the completeness, accuracy or effectiveness of any third-party notices or choices.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request. Further, there is not currently a consensus as to how various user-enabled privacy or “do not track” signals or settings should be treated or what they mean, so we will not look for or respond to any that are not expressly listed here as programs in which we participate or otherwise accept, which may change as programs evolve. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

We do not knowingly sell the PI of Consumers under 16.

We may disclose your PI for the following purposes, which are not a sale:  (i) if you direct us to share PI; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset sale; and (iv) as otherwise required or permitted by applicable law.

(C) Delete

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining.   Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.  Note also that we are not required to delete your PI that we did not collect directly from you.  

To make a request, click here. 

For all requests, we will ask for your first and last name, as well as your email address, to verify your identity. If we are unable to find you in our database or records, we will notify you.

(D) Non-Discrimination and Financial Incentive Programs

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

(E) Authorized Agents

If a Consumer chooses to submit a request through an authorized agent, we require the Consumer to:

      • Provide the authorized agent signed permission by the Consumer to submit a request, a copy of which must be provided to us;
      • Verify their own identity directly with us; 
      • Directly confirm with us that they provided the authorized agent permission to submit the request. 

If the authorized agent has a power of attorney issued under California Probate Code sections 4000 to 4465, then the written agreement is not necessary. Pursuant to Probate Code Sections 4121 and 4122, a power of attorney is only valid if it is notarized or witnessed by two adults other than the attorney-in-fact. Where witnesses are used rather than a notary, we require verification of the witnesses’ identities, and verification that they in fact witnessed the appointment. The power of attorney must be sufficiently broad, or specific, to establish agency to make a CCPA request. We are entitled to reject any request submitted through a power of attorney if the attorney-in-fact cannot reasonably verify the validity of the power of attorney.

If the authorized agent is not authorized by a power of attorney, we require an agent that is an entity be registered with the Secretary of State to conduct business in California. We are entitled to verify the legitimacy of an agency appointment, such as through a representation under the penalty of perjury with two verified witnesses.  We are entitled to require a natural person acting on behalf of an entity agent to attest under penalty of perjury with two verified witnesses that (1) they are authorized to act on behalf of the entity and the consumer; (2) they are who they claim to be; and (3) everything they have submitted is valid and accurate. We are entitled to require the same of an individual acting as an agent, except for the qualification that they be registered with the Secretary of State to do business in California.

In the absence of any of the general conditions detailed above, we are entitled to reject any request submitted through an agent. In addition, the agent is subject to the verification standards applicable to the type of request(s) made.

(F) Limitation of Rights

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights.  In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

Return to Navigation

4. ADDITIONAL CALIFORNIA NOTICES

In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

(A) Third Party Marketing and Your California Privacy Rights:

[California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.]

Separate from your CCPA “Do Not Sell” rights you have the following additional rights regarding disclosure of your information to third parties for their own direct marketing purposes:

We do not share personal information as defined by California Civil Code § 1798.83 (“Shine the Light law”) with third parties for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us here or by sending a letter to Digilant, 2 Oliver Street, Boston, MA 02109 (Attention: Privacy).  Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

(B) Online Privacy Practices:

For more information on our online practices and your California rights specific to our online services see our online Privacy Policy.  Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

Tracking and Targeting:

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on your having visited our services or your activities across time and third-party locations. Some browsers may enable you to turn on or off a so-called “Do Not Track” signal. Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals. For more information on tracking and targeting and your choices regarding these practices, see our online Privacy Policy.

California Minors: 

Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the service, can request removal by contacting us here, detailing where the content or information is posted and attesting that you posted it.  We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law.  This removal process cannot ensure complete or comprehensive removal.  For instance, third parties may have republished or archived content by search engines and others that we do not control.

Return to Navigation

5. CONTACT US

For more information on your California privacy rights contact us at +1 (844) 344 4526 or email us here. You may also use our California Consumer Rights Portal found here. Or, write to us at: Digilant, 2 Oliver Street, Boston, MA 02109.

Return to Navigation

Like what you see? Join the 500+ clients that have partnered with Digilant.