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CCPA

as data experts, we understand that the ability to use and process consumer data can only occur in an environment where we earn the trust of both the companies on whose behalf we process customer data and the individuals to whom such data relates in order to deliver mutual value to both brands and consumers

Date Last Updated: 1st September 2023

To comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws this privacy policy is for California residents and supplements the information contained in the Privacy Policy of Choreograph LLC (collectively, “Choreograph”, “we,” “us,” or “our”). This policy applies to visitors and users who are residents of the State of California (“consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this policy.

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Within the last 12 months, we have collected the following categories of personal information from consumers, or have received the following categories of personal information from other businesses:

Chart A:

Category of personal information

Category Examples

(Note: These are examples of the category and not all of this data is collected)
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, education, employment.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, religion, marital status, health data (excluding PHI), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data.
 Postal address, IP address (which is converted into country, region, or zip code level location data) and latitude/longitude data of properties/houses
G. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics,  behavior, attitudes or interests.

Personal information does not include publicly available information from government records, deidentified or aggregated consumer information.

Sources, purposes and sharing of personal information

Below outlines:

  • the business purpose and if we share the personal information,
  • how we collect or receive the categories of personal information, and
  • the categories of third parties we share personal information with.

We may share all of the information listed in Chart A for our business purposes. We may disclose your personal information to other companies in our corporate group, affiliates and third parties to help us process your personal information for the purposes set out in this policy. When we disclose personal information for a business purpose, we enter a contract that describes the purpose of the processing and prevents the recipient from retaining, using or disclosing the personal information for any purpose other than performing the contract.

For all of the categories in Chart A above, we collect personal information about consumers to provide marketing, advertising and analytics services.

For example, this may include helping clients deliver online advertising campaigns to their customers, helping clients identify new customers that are similar to their existing customers, and helping clients understand more about their customers so that they can develop better products and advertising campaigns with those customers in mind.

For all of the categories in Chart A above, we collect or receive the categories of personal information from categories of data sources listed in Chart B.

We may share or sell all of the information listed in Chart A for the purposes outlined above. The categories of third parties that we may have sold or disclosed the personal information to is outlined in the chart below:

Chart B:

Category of Company Receiving Data

Description
Advertising/Marketing Companies
Companies that provide marketing services and advertising services both online and offline. Typically, these companies are using the data to improve marketing relevance for consumers.
Apparel & Accessory Companies
Retailers and other merchants that typically sell clothing, shoes and fashion accessory products.
Automotive Companies
Car companies or companies that provide services for cars and trucks such as sales, car service, or car products.
Business to Business Companies
Companies that provide products and services for other businesses such as computer services, paper, and other products or services.
Parenting Product Companies
Retailers and other merchants that typically sell children’s products including clothing, shoes, toys, and other products.
Communication Services Companies
Companies that provide services such as home phones, cellular phones, TV services, and satellite service.
Consumer Packaged Goods Companies
Retailers and other merchants that typically sell groceries and other household products such as cleaning supplies.
Consumer Services Companies
Companies that provide consumer and residential services including storage, lawn care, home security.
Data Compiling Companies Companies that purchase data from other companies and organize the data into descriptive categorizations for use in marketing activities.
Educational Institutions & Companies
Organization and companies offering education services including colleges, training centers and certification programs.
Electronics Companies Retailers and other merchants that typically sell electronics such as computers, TV’s, phones and other electronic products.
Energy and Utility Companies
Companies that provide residential energy and water services.
Financial Services Companies
Companies that provide financial services for consumers – note no credit information, bank information, or social security numbers are ever collected or used.
Food & Beverage Companies
Retailers and other merchants that typically sell food and beverage products such as meat, vegetables, and wine.
Gift Product Companies
Retailers and other merchants that typically sell gift products such as flowers, gift baskets, and other similar products.
Public Institutions
Organizations supporting consumer interests through public programs, government programs, and other related activities.
Health Product Companies
Retailers and other merchants that typically sell health related products such as vitamins, supplements, and other related products. Note: no medical data, insurance data, or prescription data is ever collected or used.
Lifestyle & Interest Product Companies
Retailers and other merchants that typically sell specialized products for hobbies, sports, fitness, wellness, and other lifestyle related activities.
Manufacturing Companies
Companies that produce consumer products for distribution through retailers and other merchants.
Not for Profit Organizations
Not for profit companies such as Charities and Political groups that collect donations from consumers for a specific cause.
Publishing Product Companies
Companies that create and sell products including magazines, books, newsletters, and newspapers.
Technology/Computer Software Companies
Companies that provide computer related products such as computer hardware and software, web and smart phone applications
Telecommunications Companies
Companies that provide services such as home phones, cellular phones, TV services, and satellite service.
Travel, Leisure & Entertainment Companies
Companies that provide services or products related to travel and entertainment including hotels, airlines, cruises, show tickets and other similar items.

 

Sale of Personal Information

In the preceding twelve (12) months, we have sold personal information in all of the categories listed in chart A above. We do not sell personal information of persons under age 18.

Your Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information, these are explained below.

Access to your personal information and data portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request, we will disclose to you:

  • The categories of personal information we collected, disclosed, and sold about you, if any.
  • For each category of personal information we collected about you:
    • The categories of sources from which this was collected.
    • Our business or commercial purpose for collecting that personal information.
    • Our business or commercial purpose for selling or disclosing that personal information.
    • The categories of third parties with whom we disclose or sell your personal information.
    • The specific pieces of personal information we collected about you to the extent such disclosure is permitted by the CCPA.
    • For data portability requests, we will provide your personal information in a format that is readily useable and should allow you to transmit the information from us to another entity.

Opt-out of the sale of your personal information

You have the right to direct us to not sell your personal information (also referred to as the right to opt out). Once we receive your request, we will not include your personal information in any further sales unless you subsequently provide express authorization for us to do so. Our Consumer Preference Portal enables you to submit your request here or call us at the following toll-free number: 1 (888) 885-7576. We will respond to your request to opt-out within 15 days.

Deletion request

You have the right to request that we delete any of your personal information that we collected directly from you and retained. We may deny your deletion request if it is necessary for us or our service providers to retain your personal information, based upon allowed exceptions. Once we receive and verify your request, and no exception applies, we will delete and direct our service providers to delete your personal information as requested. We will contact you to confirm the deletion and the manner in which it was deleted. Please click here to make a deletion request.

Non-discrimination

We will not discriminate against you for exercising any of your rights under the CCPA.

Exercising access, opt-out, data portability and deletion rights

To exercise the rights described above please submit your request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.  If you wish to authorize an agent to submit a verifiable request, please submit a document to privacy@Choreograph.com that provides the authorized agent with signed permission to make a request on your behalf.

If you submit a request to know or a request to delete, we will verify your identity by comparing the information you provide through our online form, or by email or telephone, with the information we have on file.  In some situations, we may request further information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.

Response timing

Upon receiving a verifiable consumer request, we aim to deliver the required information within 45 days. Where we require more time (up to a further 45 days), we will inform you of the reason and extension period.  We aim to comply with all requests to opt out of sale within 15 business days.

How to contact us

If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at the following address: Privacy@Choreograph.com

Changes to this privacy policy

We review this privacy policy on a regular basis to ensure that it is up-to-date with our use of your personal information, and compliant with applicable data protection laws. We reserve the right, at our discretion, to revise this privacy policy at any time. The updated privacy policy will be posted on our website. You are encouraged to review this privacy policy from time to time.

Consumer Right’s Request Summary from July 1st 2022 to July 1st 2023

Requests to know complied with: 224 total, 161 complied with, 63 denied

Requests to delete complied with: 190 total, 182 complied with 8 denied

Requests to opt out of sale complied with: 977 complied with one denials

Median number of days to comply with: request to know 4.48; requests to delete: 4.48 (immediate); requests to opt out: 4.48 (immediate covers both types).