Additional Information for California Residents
This section of the Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act (the “CCPA”). This section does not address or apply to our handling of publicly available information or personal information that is otherwise exempt under the CCPA. Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.
Categories of Personal Information Collected and Disclosed. The following identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of other entities to whom we may disclose this information. Depending on how you interact with us, we may collect and disclose the following categories of personal information:
• Identifiers: Includes direct identifiers such as name, email, phone number, address, IP address, or other similar identifiers.
• Internet or Other Electronic Network Activity Information: Includes information regarding interactions with our website, advertisements, or emails, including other
• Location Data: Such as general location information about a particular individual or device.
• Professional Information: Includes, but is not limited to, job title, company name, business email, business phone number, current and former employer, and other similar professional-related information.
• Education Information: Includes information about an individual’s educational history, [such as the schools attended, degrees you were awarded, and associated dates].
• Protected Classifications: We may collect some information that is considered a protected classification under California or federal law, such as your date of birth.
SpendMend may disclose the above information to the following third parties and other recipients.
• Affiliates and subsidiaries
• Service providers and vendors
• Advisors and agents
• Others as required by law
Sources of Personal Information: In general, we may collect the categories of personal information identified in the list above from the following categories of sources:
• Vendors and service providers
• Business customers and clients
Purposes of Collection, Use, and Disclosure: As described in more detail above under the “How We May Use Your Information” and “How We Share Your Information” sections, we collect, use, and disclose the above personal information for the following business or commercial purposes and as otherwise directed by you:
• Services and support
• Marketing and advertising
• General business and operational support
• Legal proceedings and obligations
• In support of business transactions (e.g., if we are acquired by another company)
Sensitive Personal Information: Notwithstanding the above, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by clients, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent, and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes that are not for inferring characteristics about you. We do not use or disclose sensitive personal information other than as authorized by the CCPA (pursuant to Cal. Civil Code § 1798.121 and § 7027(m) of the CCPA regulations).
De-identified Information: We may use, disclose, or process de-identified data. We will maintain and use the de-identified information in deidentified form, and we will not attempt to reidentify the information, except to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.]
Sale or Sharing of Personal Information: The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).
Retention of Personal Information: We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
California Privacy Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:
• Right to Know. You have the right to request: (i) the categories or personal information we collected about you; (ii) the categories of sources from which the personal information is collected; (iii) our business or commercial purposes for collecting, selling, or sharing personal information; (iv) the categories of third parties to whom we have disclosed personal information; and (v) a copy of the specific pieces of personal information we have collected about you.
• Right to Delete. You have the right to request we delete personal information we have collected from you.
• Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
• Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA.
• Right to Limit Use and Disclosure. You have the right to limit use and disclose of your sensitive personal information. [We do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA; thus, this right is not available to California residents.]
• Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.
Exercising Your Privacy Rights. California residents may exercise their CCPA privacy rights as set forth below:
• Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal information by emailing the privacy officer at privacy@spendmend.com or calling 1-888-257-6748.
When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at privacy@spendmend.com, and include in your request a current California address and your attestation that you are a California resident.