California Privacy Notice
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.
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: 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.
- Any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code: 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.
Protected Classifications: 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: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Online Activity: 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.
- Geolocation Data: data that is derived from a device and is used or intended to locate an individual within a geographic area.
- Sensory Information: Audio, electronic, visual, thermal, olfactory, or similar information.
Employment Information: Professional or employment-related information.
- Inferences 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.
Sensitive Personal Information: 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.
Communications Data: such as the nature and content of communications, date and time sent, etc.
- Survey Response Data: 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
|
Purposes |
Purposes 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 |
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 |
Short-term, transient use, including, but not limited to, non- personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business |
|
-Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business |
|
Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, a service provider or contractor shall not combine the personal information of opted-out consumers that the service provider or contractor receives from, or on behalf of, the business with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers |
-Identifiers |
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. |
-Identifiers |
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 |
Information received from you as part of communications with us |
-Identifiers |
Your device, systems, browsers, and equipment when you access our platforms or Services |
-Identifiers |
Collected from Social Networks |
N/A |
Collected from market enrichment partners |
N/A |
Collected from advertising partners |
N/A |
Collected from payment providers |
-Identifiers |
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 |
|
-Identifiers |
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 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
|
Purposes |
Categories of Personal Information |
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business |
-Identifiers |
-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 |
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
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 |
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 (Cookies and Similar Technologies) of the General Privacy Policy |
-Identifiers |
(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’ group of companiesVendors providing services to us or on our behalf |
-Identifiers |
(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 Requests Received |
Completed |
Denied – |
Denied on Other Grounds (i.e., revoked by submitter) |
Median Number of Days for Response |
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 8 (Your Rights and Choices) of the General Privacy Policy.
