California Privacy Notice
Effective Date: November 1, 2023
Related Documents:
California Residents. For California residents that are individuals covered by the Sky Analytica General Privacy Policy, this California Privacy Notice (“Notice”) provides supplementary and important disclosures. Please note that certain sections of this Notice reference back to the General Privacy Policy (such as detailed information on how to exercise privacy rights). Capitalized terms used in this Notice but not defined herein, shall have the meaning ascribed to such terms in the General Privacy Policy. All references to a “consumer” in this Notice shall include the categories of data subjects covered by this Notice who are residents of the State of California. For clarification, all references to “business” shall mean Sky Analytica.
A. California Privacy Rights Act (“CPRA”) Disclosures.
i. USERS:
a. Notice at Collection.
1. In addition to the other categories of personal information that are identified as being collected from or about Users in Section 2.A. of the General Privacy Policy, we collect the following categories of personal information about or about you:
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, phone number, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Information such as signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information.
Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, disability, citizenship status, and military and veteran status.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding an individual’s interaction with an internet website application, or advertisement.
Data that is derived from a device and is used or intended to locate an individual within a geographic area.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Inferences drawn from any of the information identified collected from or about you to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
As this term is defined under the CPRA, including, as applicable, precise geolocation; a social security, driver’s license, state identification card, or passport number; racial or ethnic origin; religious beliefs; mental or physical health diagnosis; sex life or sexual orientation; or citizenship; etc. We do not use or disclose your sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer, for security and legal reasons, with your consent, and/or for other purposes permitted by applicable law.
Such as the nature and content of communications, date and time sent, etc.
Such as demographic information and survey responses that you provide when you voluntarily participate in a survey for us.
2. We may use the categories of personal information listed above for the purposes described in Section 2.A. of the General Privacy Policy. In addition, for CPRA compliance purposes, we use the personal information for purposes (business and commercial) as described:
| Purpose | Categories of Personal Information |
|---|---|
| Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards | Identifiers, Online Activity |
| Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, Sensitive Personal Information, Communications Data, Survey Response Data |
| Short-term, transient use, including non-personalized advertising shown as part of a consumer’s current interaction with the business | Identifiers, Commercial Information, Online Activity, Geolocation Data |
| Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing payments, providing analytic services; Undertaking internal research for technological development | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, Inference Information, Sensitive Personal Information, Communications Data, Survey Response Data |
| Providing advertising and marketing services, except for cross-context behavioral advertising | Identifiers, Commercial Information, Online Activity, Geolocation Data, Inference Information, Survey Response Data |
| Undertaking activities to verify or maintain the quality or safety of a service or device, and to improve, upgrade, or enhance the service or device | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, Sensitive Personal Information, Communications Data, Survey Response Data |
3. For the categories of personal information collected, the personal information is retained in accordance with Section 5 (Data Retention) of the General Privacy Policy.
4. For this group or category of consumer, Sky Analytica does not sell or share, as those terms have meaning under California law, the following categories of personal information:
- Identifiers
- Protected Classifications
- Commercial Information
- Online Activity
b. Prior Collection, Use and Disclosure of Personal Information.
We may have collected and used your personal information, as described in Section A.i.a. of this Notice, during the preceding 12 months. For the personal information collected during this period, we describe below: (1) the categories of sources from which we have collected the personal information, (2) the categories of third parties with whom we have disclosed your personal information for our business or commercial purposes, (3) the categories of personal information we have disclosed for a business purpose, and (4) the categories of third parties to whom we have sold or shared personal information and purpose(s) for which the personal information was sold or shared.
(1) Categories of sources from which we have collected the personal information:
| Categories of Sources | Categories of Personal Information |
|---|---|
| Information you provide directly to us, when you complete a form, complete a survey, etc. | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Protected Classifications, Commercial Information, Sensory Information, Employment Information, Sensitive Personal Information, Communications Data, Survey Response Data |
| Information received from you as part of communications with us | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Protected Classifications, Commercial Information, Employment Information, Communications Data |
| Your device, systems, browsers, and equipment when you access our platforms or Services | Identifiers, Online Activity, Geolocation Data, Sensitive Personal Information |
| Collected from Social Networks | N/A |
| Collected from market enrichment partners | N/A |
| Collected from advertising partners | N/A |
| Collected from payment providers | Identifiers, Any personal information described in subdivision (a) of Section 1798.80 |
| Collected from business partners | N/A |
(2) Categories of third parties with whom we have disclosed the information for our business or commercial purposes:
| Categories of Third Parties | Categories of Personal Information |
|---|---|
| Our affiliates; Vendors providing services to us or on our behalf; Professional services organizations; Any entity required by law; Third parties for business transactions; Persons you direct us to disclose to | Identifiers, Any personal information described in subdivision (a) of Section 1798.80, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, Sensory Information, Employment Information, Inference Information, Sensitive Personal Information, Communications Data, Survey Response Data |
| Social Networks (e.g., when you sign-in or connect your User account with a Social Network account, etc.) | N/A |
(3) Categories of personal information that we have disclosed for a business purpose:
See the categories of personal information described in Section A.i.a.1. of this Notice.
(4) Categories of third parties to whom personal information has been sold or shared and the purpose(s) for which the personal information was sold or shared:
NONE.
ii. NON-USERS:
a. Notice at Collection.
1. In addition to the other categories of personal information that are identified as being collected from or about Non-Users in Section 2.B. (Non-Users) of the General Privacy Policy, we collect the following categories of personal information about you:
- Identifiers
- Commercial Information
- Online Activity
- Communications Data
2. We may use the categories of personal information listed above for the purposes described in Section 2.B. (Non-Users) of General Privacy Policy. In addition, for CPRA compliance purposes, we use the personal information for purposes (business and commercial) as described:
| Purpose | Categories of Personal Information |
|---|---|
| Short-term, transient use, including non-personalized advertising shown as part of a consumer’s current interaction with the business | Identifiers, Online Activity |
| Helping to ensure security and integrity; Debugging; Performing services on behalf of the business; Providing advertising and marketing services; Undertaking internal research; Undertaking activities to verify or maintain quality or safety | Identifiers, Commercial Information, Online Activity, Communication Data |
3. For the categories of personal information collected, the personal information is retained in accordance with Section 5 (Data Retention) of the General Privacy Policy.
4. We do not sell or share any of the categories of personal information collected from or about this group or category of consumer.
b. Prior Collection, Use and Disclosure of Personal Information.
We may have collected and used your personal information, as described in Section A.ii.a. of this Notice, during the preceding 12 months. For the personal information collected during this period, we describe below: (1) the categories of sources from which we have collected the personal information, (2) the categories of third parties with whom we have disclosed personal information for our business or commercial purposes, and (3) the categories of personal information we have disclosed for a business purpose.
(1) Categories of sources from which we have collected personal information:
| Categories of Sources | Categories of Personal Information |
|---|---|
| You, when you communicate with us (e.g., Contact us about an order or communication, etc.) | Identifiers, Communications Data |
| Your device, systems, browsers, and equipment when you access our platforms or Services, which deploy or use cookies and similar technologies as described in Section 3 of the General Privacy Policy | Identifiers, Online Activity |
(2) Categories of Third Parties with whom we disclosed personal information for our business and commercial purposes:
| Categories of Third Parties | Categories of Personal Information |
|---|---|
| Sky Analytica’s group of companies; Vendors providing services to us; Professional service organizations; Any entity required by law; Third parties for business transactions; Persons you direct us to disclose to | Identifiers, Commercial Information, Online Activity, Communications Data |
(3) Categories of personal information we have disclosed for a business purpose:
See the categories of personal information described in Section ii.a.1 of this Notice.
B. Metrics:
Applicable Period: January 1, 2022 – December 31, 2022
Scope: The below metrics apply to all requests received from all California residents during the Applicable Period.
| Request Type | Total Received | Completed | Denied | Denied (Other) | Median Days |
|---|---|---|---|---|---|
| Request to Know | 0 | 0 | 0 | 0 | N/A |
| Request to Delete* | 0 | 0 | 0 | 0 | N/A |
*The number of deletion requests is inclusive of (i) requests to delete personal information as a privacy right and (ii) requests to delete information and/or Sky Analytica accounts as an account management function (e.g., this reporting is not solely limited to the privacy right to delete personal information).
C. Notice of Financial Incentives:
NONE.
D. California Shine the Light Law.
The “Shine the Light” requirements under California Civil Code 1798.83 do not apply to the individuals covered under the General Privacy Policy and this Notice because we do not engage in activities covered by this law.
E. CPRA Rights.
Under the CPRA, you have certain rights, including:
- The Right to Delete
- The Right to Correct
- The Right to Know and Access
- The Right to Opt out of Sale or Sharing and the right to opt-in after having opted-out
- The Right to Limit Use and Disclosure of Sensitive Personal Information
- The Right of Non-Retaliation if you choose to exercise any of these rights
You may exercise these rights by going to Section 7 (Your Rights and Choices) of the General Privacy Policy.