This California Privacy Notice (“Notice”) supplements the information contained in LCPtracker’s general Privacy Policy and applies solely to “personal information” that is subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.

Please note that LCPtracker may act as either a “business” or a “service provider” (as defined by the CCPA) depending on the activity. For example, we act as a service provider when making available our SaaS application(s) to our administrative customers pursuant to a written agreement. We act as a business in certain other circumstances such as when marketing LCPtracker services, products, or events to users of our Platform.

Personal Information We Collect and Disclose

We collected the following categories of personal information about California consumers within the last twelve (12) months:

• Personal and online identifiers (such as name, alias, postal address, government-issued identification number, birthdate, age, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers).
• Categories of information described in section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information).
• Characteristics of protected classifications under California or federal law (such as race or gender).
• Commercial or transactions information (such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
• Internet or other electronic network activity information (such as browsing history, search history, information about a consumer’s interaction with a website, application, or advertisement).
• Geolocation information.
• Professional or employment-related information (such as your employee ID number, resume, employment history, apprentice training program history, wage history, occupation history, references, and professional organization membership information).
• Inferences drawn from the above information about your predicted characteristics and preferences.
• Other information about you that is linked to the personal information above.

Some of the categories of personal information listed above are considered sensitive personal information under the CCPA.  We do not use or disclose sensitive personal information, as defined by the CCPA, for purposes other than those specified in the CCPA. Additionally, we do not knowingly sell or share the personal information of individuals under age 16, and we request that customers do not share this information with us.

Categories of Sources

We obtain the categories of personal information listed above from the following categories of sources:

• You.
• Our customers. 
• Our affiliates and joint venture partners. 
• Our business partners. 
• Our service providers. 
• Advertising companies and networks. 
• Social media platforms and networks. 

Use of Personal Information

We may use or disclose the personal information we collect for our commercial and business purposes, including:

• Providing, operating, improving, and personalizing our Platform and business.
• Detecting security incidents and preventing fraud.
• Communicating with you, including about your account or our business relationship.
• Advertising and marketing our services and those of our affiliates, business partners, including third-party marketing partners, and other select third parties.
• Performing analytics and quality control.
• Researching and testing to improve our services.
• For legal compliance purposes.
• With your consent or for other purposes described at the point of collection.

We may use and share aggregated and deidentified information to the extent permitted by applicable law.   When we use deidentified information, we maintain and use the information in deidentified form and do not attempt to reidentify it, except to check whether our deidentification processes satisfy the requirements of applicable law. 

Recipients of Personal Information

We may disclose the categories of personal information designated above to the following categories of third parties for commercial and business purposes: 

• Our customers. 
• Our affiliates and joint venture partners.
• Our business partners.
• Our service providers. 
• Advertising companies and networks.  
• Social media platforms and networks. 
• Government entities. 

We may sell or share the categories of personal information designated above to advertising companies and networks. 

Your Rights and Choices

The CCPA provides California residents with specific rights with respect to personal information collected by businesses. If you are a California resident, this section describes your CCPA rights and explains how you may exercise those rights, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, sell, and share about you; the categories of sources from which we collected personal information about you; our business or commercial purpose for collecting or selling personal information about you; the categories of personal information about you that we have either sold, shared, or disclosed for a business purpose; and the categories of third parties to whom we have disclosed personal information. 
• The right to request that we delete any personal information that we collected from you and retained, subject to certain exceptions. 
• The right to request correction of inaccurate personal information we maintain about you. 
• The right to opt out of our sale(s) or sharing of personal information.  Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales. 
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.