California Consumer Privacy Act (“CCPA”) Notice
Last Updated: October 16, 2023
This California Consumer Privacy Act, as amended by the California Privacy Act, (collectively, “CCPA”) Privacy Notice is included in our Privacy Policy and applies to our processing of personal information related to California consumers who are visiting our Sites, using the MyBambu App, or otherwise interacting with us. As outlined in our Privacy Policy, personal information of our users that we collect in connection with the solicitation and/or provision of our financial Services is subject to our GLBA Privacy Notice. In the event of conflict or inconsistency between this Privacy Policy and our GLBA Privacy Notice, the GLBA Privacy Notice will apply to that personal information.
Our Collection of Personal Information
We collect personal information you when you (i) visit our Sites or download the MyBambu App, (ii) request additional information about our Services or the MyBambu App, or (iii) otherwise interact with us, including the following categories and types of personal information:
Category of Personal Information Collected | Types of Personal Information | Source of Personal Information | Business Purpose for Collection of Personal Information |
Identifiers | Name, Postal Address, Unique Personal Identifiers, Online Identifiers, IP Address, Email Address, Account Name/Password, Signature, Photo ID, Telephone Number, Bank Account Number, Financial Information. | Directly from the users of our Services or potential users, Cookies and Other Tracking Technologies, Third Parties, including Credit Bureaus and those that provide identification verification and fraud prevention services, Public Databases, Social Media Platforms. | Identification, Providing Services, Legal & Regulatory Compliance |
Protected Characteristics | Sex (Gender Identity), National Origin, Age. | Directly from the users of our Services or potential users. | Identification, Providing Services, Legal & Regulatory Compliance |
Sensitive Personal Information | Social Security Number, Driver’s License Number, State Identification Card, Passport Number, Log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, Precise Geolocation. | Directly from the users of our Services or potential users, Cookies and Other Tracking Technologies, Third Parties, including Credit Bureaus and those that provide identification verification and fraud prevention services. | Identification, Providing Services, Legal & Regulatory Compliance |
Biometric Information | Behavioral or activity patterns used to extract a template or other identifier or identifying information, such as keystroke or other physical patterns. | Cookies and Other Tracking Technologies. | Identification, Providing Services, Legal & Regulatory Compliance |
Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Directly from the users of our Services or potential users, Cookies and Other Tracking Technologies, Third Parties, including Credit Bureaus and those that provide identification verification and fraud prevent services, Public Databases, Social Media Platforms. | Identification, Providing Services, Legal & Regulatory Compliance |
Internet, computer, or other similar network activity | Browsing History, Search History, Information Regarding Interactions with a Website. | Cookies and Other Tracking Technologies. | Identification, Providing Services, Legal & Regulatory Compliance |
Geolocation Data | Location or Movements | Cookies and Other Tracking Technologies. | Identification, Providing Services, Legal & Regulatory Compliance |
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | Audio, Electronic, Visual, or Similar Information, including Phone Call Recordings. | Cookies and Other Tracking Technologies. | Identification, Providing Services, Legal & Regulatory Compliance |
Inferences Drawn from Other Personal Information | Profile information about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Directly from the users of our Services or potential users, Cookies and Other Tracking Technologies, Third Parties, including Credit Bureaus and those that provide identification verification and fraud prevent services, Public Databases, Social Media Platforms. | Identification, Providing Services, Legal & Regulatory Compliance |
Sharing Your Personal Information
We do not sell your personal information; however, we may share your personal information with the following categories of third parties as further outlined in our Privacy Policy:
- Third-Party Service Providers
- Our Affiliates
- Legal & Regulatory Authorities
Notice of Financial Incentive
We offer certain loyalty programs that involve the collection of personal information as described in this CCPA Privacy Notice and our Privacy Policy. This may be considered a “financial incentive” under California law. The value of your personal information to us is related to the value of the free or discounted products or Services, or other benefits that you obtain or that are provided as part of the loyalty program, less the expenses relate to offering those products, Services, and benefits. You may revoke your consent to participate or receive such financial incentive at any time by contacting us at [email protected].
Your Privacy Rights and Choices
California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and storage of their personal information.
Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:
- The categories of personal information we have collected about you.
- The categories of sources for the personal information we have collected about you.
- The specific pieces of personal information we have collected about you.
- Our business or commercial purpose for collecting or selling your personal information.
- The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.
Your Right to Opt-Out of Sale or Sharing of Personal Information: Under the CCPA, as amended by the CPRA, California residents have the right to opt-out of the sale of their personal information and/or the sharing of personal information with third parties for the purposes of cross-contextual behavioral advertising or profiling by submitting a request. Please note that we do not sell personal information, including the personal information of any individuals under the age of 16, nor do we share any personal information for the purposes of cross-contextual behavioral advertising.
Your Right to Limit Use of Sensitive Personal Information: California residents have the right to request that we limit our use of any sensitive personal information to those uses, which are necessary to perform the Services or for other business purposes under the CCPA, as amended by the CPRA.
Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, as amended by the CPRA, we will delete, and direct our third-party service provides to delete, your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA, as amended by the CPRA.
Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA, as amended by the CPRA.
Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.
Responding to Your Request: We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we reasonably require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Under the CCPA, we are only obligated to respond to requests twice per twelve-month period.
Retention of Personal Information
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless otherwise permitted or required by law.
Contact Information
If you have any questions or comments about this CCPA Privacy Notice, our Privacy Policy or the ways in which we collect and use your personal information or to exercise any of your rights under California law, please do not hesitate to contact us:
- by writing us at P.O. Box 171 West Palm Beach, FL 33402; or
- by calling the Customer Service: (833) 882-2628
- and by emailing us at [email protected].
