GlowUp California Consumer Privacy Statement

Effective: August 22nd, 2022

 

This California Consumer Privacy Statement supplements the GlowUP Privacy Policy and applies solely to California consumers. This Statement does not apply to job applicants.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

 

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers
• Protected Classifications: characteristics of protected classifications under California or federal law, such as age and gender
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in the SNOW Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

Purposes

Categories of Personal Information

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Debugging to identify and repair errors that impair existing intended functionality

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Undertaking internal research for technological development and demonstration

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

 

2. Our Prior Collection, Use, and Disclosure of Personal Information

We may have collected and used your personal information, as described in Section 1 of this Statement, during the 12-month period prior to the effective date of the Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection

Categories of Personal Information

Directly from you

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

From your devices

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

Our affiliates

• Identifiers

• Online Activity

• Sensory Information

• Inferences

Vendors who provide services on our behalf

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties

Categories of Personal Information

Categories of Third Parties

Categories of Personal Information

Our affiliates

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

Vendors who provide services on our behalf

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Professional services organizations, such as auditors and law firms

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

Our SNOW Partners

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

Advertising networks

• Identifiers

• Online Activity

• Inferences

Data analytics providers

• Identifiers

• Commercial Information

• Online Activity

• Sensory Information

• Inferences

Sale of Personal Information

SNOW use Advertising networks to show Interest-Based Advertising in their apps and may sell personal information using Advertising networks. During the 12-month period prior to the effective date of this California Consumer Privacy Statement, the following categories of personal information may have been sold using our Services:
• Identifiers such as a real name, alias, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
• Internet and other electronic network activity information, including, but not limited to, your interaction with websites, applications or advertisements
• Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences and characteristics predispositions, behavior, and attitudes.

We do not sell the personal information of minors we know to be under 16 years of age.

Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose the following categories of personal information:
• Identifiers
• Online Activity
• Sensory Information
• Inferences

 

3. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request. To submit an access or deletion request, email us at sn_service_privacy@snowcorp.com. To opt-out of the sale of your personal information, click here or email us at sn_service_privacy@snowcorp.com.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact sn_service_privacy@snowcorp.com or to request this Statement in an alternative format.