Privacy Notice for California Residents

Last updated: March 2022

This PRIVACY POLICY FOR CALIFORNIA RESIDENTS (“California Privacy Policy”) supplements the information contained in the Civex Privacy Policy (“Privacy Policy”) and applies solely to California residents who visit or use the Civex System (as such term is defined in the Civex Privacy Policy). This California Privacy Policy describes the personal information that Civex collects about you, the rights you have with respect to that information and how you can exercise those rights. Civex adopts the California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Online Privacy Protection Act (“CalOPPA”) and any terms defined in the CCPA and CalOPPA have the same meaning as used herein. In this California Privacy Policy, “we,” “us,” and “our” refer to Civex and “you” and “your” refer to you, an individual.

Civex values the privacy of our customers and we take measures to implement reasonable security controls for the protection of our customers’ information. California law and, more specifically, the CCPA define ‘personal information’ broadly as information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It could include identifiers, such as IP addresses or device identifiers, in addition to names and addresses. This California Privacy Policy provides additional information regarding Civex’s practices and your rights if you are a resident of California.

The CCPA does not apply to personal information we collect as part of our current or former customer relationship with you pursuant to other privacy laws, such as the federal Gramm-Leach-Bliley Act (“GLBA”). What we do with personal information of our customers governed by the GLBA is set forth in the Civex Privacy Policy. Depending on whether you have or had a customer or other business relationship with us, including any potential, current or former employment relationship, the CCPA may not apply to you or all of your personal information.

Information We Collect

Please see the section entitled “Information We Collect” under the Privacy Policy.

Source(s) of Personal Information

Please see the section entitled “Information We Collect” under the Privacy Policy.

Use of Personal Information 

Please see the section entitled “How We Use Your Information” under the Privacy Policy.

Sharing Personal Information

Please see the section entitled “How We Share Your Information” under the Privacy Policy.

Additionally, please note that we may disclose your personal information to a third-party for a business purpose and for other reasons as permitted by law. 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 disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • To a third party in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • To other persons or entities where you consent to the disclosure.

We may also disclose your personal information to comply with laws, legal processes and law enforcement to the following categories of third parties:

  • To government, law enforcement officials, regulators and others as we believe is necessary or appropriate to respond to claims and legal processes (including subpoenas and administrative summonses), to protect the property and rights of Civex or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be illegal, unethical or legally actionable.

In the preceding twelve (12) months, we have disclosed the following categories of personal information to our service providers including Google Analytics, to help us analyze use of the Civex System:

  • Identifiers
  • Internet or other similar network activity

We do not sell your personal information for money and we do not share your personal information with third parties in a manner that is construed as a “sale” under the CCPA. The concept of a “sale” under CCPA is different from what has traditionally been considered a “sale” (e.g., selling a customer list for money). Under the CCPA, a “sale” potentially includes other uses or disclosures of personal information to third parties outside Civex in a commercial context where an exception to “sale”, as provided by the CCPA, does not exist.  Civex does not knowingly “sell” any personal information.  

Your Rights and Choices

The CCPA provides consumers, who are California residents, with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about what personal information we collect, use, disclose and sell. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we have collected about you in the last (12) months, why we have collected it and whether we have disclosed that information for a business purpose.
  • The categories of sources from which we collect personal information.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Rights Requests

You have the right to request that we delete your personal information we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of such information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to the email or physical address set forth below in the Contact Information Section.

Only you, or a person that you authorize to submit a request to know your personal information or to delete your personal information on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative).
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If you submit a request to know or delete personal information, we will verify your identity. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Opt-out of the Sale of Your Personal Information

Where a business sells your personal information, you have the right to opt-out of the sale of that personal information. Civex does not sell your personal information.

Non-Discrimination

You have the right not to receive discriminatory treatment by us because you have exercised your privacy rights. This means that you have the right not to be denied goods or services, charged different prices or provided a different level or quality of services, just because you have exercised your privacy rights.

Correction of Information Collected From You Online

CalOPPA provides you with the right to correct the information that we collected about you online. If you entered information online and later need to correct that information, please contact us at the email or physical address set forth below. Please note that if we cannot associate the information to you, we may not be able to correct it.

Changes to Our Privacy Policy

We reserve the right to amend this California Privacy Policy at our discretion and at any time. If we materially change this California Privacy Policy, we will post the updated notice on our Services and update the notice’s effective date. Your continued use of the Civex System following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions or comments about this California Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such collection or use, or wish to exercise your rights under California law, you may contact us via email at: privacy@civex.io or write to us at: 

Civex LLC
9 West Broad Street, Suite 320
Stamford, CT 06902

©2022 Civex LLC