Additional California Privacy Disclosures
Beginning January 1, 2020, the California Consumer Privacy Act ("CCPA") gives California residents certain rights with respect to the processing of personal data (known as "personal information" under the CCPA).
Additionally, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@feinternational.com.
This supplement provides additional privacy disclosures and details additional rights, and should be read in conjunction with our [Privacy Policy].
Personal Information Collected and Processed
Under the CCPA, California residents have certain rights regarding their data, including:
- The right to know the categories of personal information we have collected and the categories of sources from which we obtained that information (see Information We Collect About You and How We Collect It in our Privacy Policy, and the chart below)
- The right to know the business purposes for sharing personal information (see How We Use Your Information in our Privacy Policy)
- The right to know the categories of third parties with whom we have shared personal information (see Disclosure of Your Information in our Privacy Policy)
- The right to access the specific pieces of personal information we have collected, and the right to delete your information (see Requests to Exercise Your Rights below)
California residents also have the right not to be discriminated against for choosing to exercise their privacy rights.
Categories of Personal Information under CCPA
- Identifiers
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Collection and Use: We collect this information to enable and improve use of the Website and our services, to understand how our users interact with the Website, to communicate with you, and to allow you to register an account on the Website.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: A name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collection and Use: We may collect your address or the address of your business when you use certain tools on our platform, and we collect it solely to allow you to effectively use those tools.
- Protected classification characteristics under California or federal law
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collection and Use: We do not collect this information.
- Commercial information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collection and Use: We do not collect this information.
- Biometric information
Examples: Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collection and Use: We do not collect this information.
- Internet or other similar network activity
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Collection and Use: We do not directly collect this information, but some of our third-party service providers, such as HubSpot and Google Analytics, collect this information on our behalf in order to provide services to us.
- Geolocation data
Examples: Physical location or movements.
Collection and Use: We do not collect this information.
- Sensory data
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collection and Use: We do not collect this information.
- Professional or employment-related information
Examples: Current or past job history or performance evaluations.
Collection and Use: We do not collect this information.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collection and Use: We do not collect this information.
- Inferences drawn from other personal information
Examples: A profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collection and Use: We do not collect this information.
Requests to Exercise Your Rights
Right to Know Request
Under the CCPA, you have the right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and to ask that we provide you with the following:
- Categories of and specific pieces of personal information we have collected about you.
- Categories of sources from which we collect personal information.
- Purposes for collecting personal information.
- Categories of third parties with which we share personal information.
- Categories of personal information disclosed about you for a business purpose.
- If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
To make a verifiable request, please email privacy@feinternational.com.
Right to Delete Request
You also have the right to request that we delete personal information, subject to certain exceptions. You may exercise this right by emailing privacy@feinternational.com.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. In some cases, we will de-identify or anonymize your personal information in order to prevent fraud or to determine whether you are a former user if you decide to re- register on the FE International platform.
Household Requests
We currently do not collect household data. If all members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.
Requests — General
Please note that if you do not have a registered buyer or seller account on the FE International marketplace platform, we may not have sufficient information about you to verify your Right to Know and Right to Delete requests. In such cases, we will be unable to verify and honor your requests.
You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.
Requests Made Through Authorized Agents
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
Sale of Personal Information
We do not sell your personal information to anyone.
Contact
For any questions regarding these California Privacy Disclosures, please contact us at:
Email: privacy@feinternational.com