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CCPA Privacy

Effective: January 1, 2020
Last updated: December 20, 2019
This CCPA Privacy Notice (this “Privacy Notice”) supplements, and should be read in conjunction with Signifyd’s (“Signifyd, “we,” or “us”) Privacy Policy and is only applicable to California residents. This notice is being published to comply with the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and the rules promulgated thereunder, as amended or superseded from time to time (the “CCPA”). Any terms used in the Privacy Notice that are not defined shall have the meaning set forth in the CCPA.
  1. The Information We Collect
  2. This Privacy Notice describes how we collect, use, disclose and otherwise process information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”) from users of our Website at www.signifyd.com (the “Site”) and our SIGNIFYD fraud and abuse prevention service provided through our customer portal on the Site (the “Service”), as well as all related applications, widgets, software, tools, and other services provided by us or on which a link to this policy is displayed (collectively, together with the Site and our Service, our “Services”).

    In particular, the Services may have collected the following categories of personal information about its customers, potential customers and Site visitors within the last 12 months:

    Category Example Collected Source*
    A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
    • Directly from you
    • From your device or your use of our website
    • From marketing service providers
    B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy 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. YES
    • Directly from you
    • From your device or your use of our website
    • From marketing service providers
    C. Protected classification characteristics under California or federal law. Age, 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). NO N/A
    D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO N/A
    E. Biometric information. 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. NO N/A
    F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES From your device or your use of our website
    G. Geolocation data. Physical location or movements. YES From your device or your use of our website
    H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES Directly from you For example, with your consent, we may record phone calls.
    I. Professional or employment-related information. Current or past job history or performance evaluations. YES Business contact information from third party data providers.
    J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). 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. NO N/A
    K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES From marketing and advertising service providers.
    * Please refer to Section 2 for additional information on “Source” and Section 1 of our Privacy Policy for more information about the information we collect.

    Personal information does not include:

    1. Publicly available information from government records;
    2. Deidentified or aggregated information; or
    3. Other information excluded from the CCPA’s scope.
  3. Sources of Personal Information
  4. Signifyd obtains the categories of personal information listed in the table above from the categories of sources specified therein. Examples of sources and when information would be collected are listed below.

    Directly from you. For example, when creating an account, signing up for a newsletter, receiving products and/or services.

    From your Device or your use of our Services. For example, from observing your actions on our website or via automated means such as web beacons (as defined in our Privacy Policy), device fingerprinting and similar technologies.

    From third parties. For example, from public databases, social media platforms, industry-standard data vendors.

  5. How We Use Your Personal Information
  6. We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

    Purpose Categories of Personal Data*
    Provide services and information that you request, respond to comments and questions, and otherwise provide support to users; A, B, F, G, H, I, K
    Enhance, improve, operate, and maintain our Services, our programs, services, website, and other systems, including to protect against and prevent fraud; A, B, F, G, H, I, K
    Prevent fraudulent use of our Services; A, B, F, G, H, K
    Tailor your user experience; A, B, F, G, K
    Maintain a record of our dealings with you; A, B, F, G, H, I, K
    Understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, features, and functionality; A, B, F, G, I, K
    Contact you for administrative and information purposes—this may include providing customer service or sending communications, including changes to our terms and conditions; A, B, F, G, I, K
    Develop and provide promotional and advertising materials that may be useful, relevant, valuable, or tailored to you, or otherwise of interest; A, B, F, G, I, K
    Achieve business purposes, such as account verification, audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention; A, B, F, G, H, I, K
    Enforce our applicable Terms of Service or other contract or as necessary to establish, exercise or defend legal rights; A, B, F, G, H, I,K
    To respond to requests from law enforcement or other governmental entities. A, B, F, G, H, I, K
    Achieve purposes for which we provide specific notice at the time of collection. A, B, F, G, H, I, K
    Please refer to the categories of data listed in Section 1.

  7. How We Disclose Your Personal Information
  8. We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights).

    We share your personal information with the categories of third parties identified in the table in Section 1 and for the following general purposes:

    • Service Providers: We also may disclose personal information to third-party service providers that assist us with our operations. For example, data subject access-request or verification management, analytics, contract management, log management, payment processing and data storage and processing facilities).
    • Protecting our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
    • Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
    1. 4.1 Disclosures of Personal Information for a Business Purpose
    2. In the preceding twelve (12) months, we may have disclosed the following categories of personal information for a business purpose:
      Category Disclosed for a Business Purpose
      Category A: Identifiers. Yes
      Category B: California Customer Records personal information categories. Yes
      Category C: Protected classification characteristics under California or federal law. No
      Category D: Commercial information. No
      Category E: Biometric information. No
      Category F: Internet or other similar network activity. Yes
      Category G: Geolocation data. Yes
      Category H: Sensory data. Yes
      Category I: Professional or employment-related information. Yes
      Category J: Non-public education information. No
      Category K: Inferences drawn from other personal information. Yes

    3. 4.2 Sales of Personal Information
    4. In the preceding twelve (12) months, we may have sold the following categories of personal information:
      Category Sale of Personal Information
      Category A: Identifiers. Yes
      Category B: California Customer Records personal information categories. No
      Category C: Protected classification characteristics under California or federal law. No
      Category D: Commercial information. Yes
      Category E: Biometric information. No
      Category F: Internet or other similar network activity. Yes
      Category G: Geolocation data. No
      Category H: Sensory data. No
      Category I: Professional or employment-related information. Yes
      Category J: Non-public education information. No
      Category K: Inferences drawn from other personal information. Yes

  9. Your Rights and Choices
  10. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    1. 5.1 Access to Specific Information and Data Portability Rights If you are a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
      • The categories of personal information we collected about you.
      • The categories of sources for the personal information we collected about you.
      • Our business or commercial purpose for collecting or selling that personal information.
      • The categories of third parties with whom we share that personal information.
      • The specific pieces of personal information we collected about you (also called a data portability request).
      • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
        • sales, identifying the personal information categories that each category of recipient purchased; and
        • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    2. 5.2 Deletion Request Rights If you are a California resident, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, 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.
    3. 5.3 Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Third parties authorized to act on your behalf may be required to provide evidence of the authorization absent circumstances where such authority is apparent. Regardless of any third party authorization, we still require the subject of an access or deletion request to verify their identity. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
      • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative registered with the California Secretary of State.
      • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
      We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. You will be asked for (1) basic contact information sufficient for us to identify you in our systems and (2) evidence of identity and California residency. We will provide a secure mechanism for you to provide evidence. We reserve the right to (1) require you to provide a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request or that you have legal authority to request information on the individual’s behalf, (2) require you to verify that you have access to the e-mail address that we have on file and/or (3) request additional information and/or to use industry standard third party identity verification providers. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. These additional verification measures are intended for your protection and to minimize the risk of improper disclosure. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
    4. 5.4 Response Timing and Format

      We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days from the date of receiving your request), we will inform you of the reason and extension period in writing.

      We will deliver our written response electronically.

      Any disclosures we provide will only cover the 12-month period preceding the date of the verifiable consumer request’s receipt. 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.

      We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    5. 5.5 Personal Information Sales Opt-Out and Opt-In Rights If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
  11. Non-Discrimination
    • We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
      • Deny you goods or services.
      • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      • Provide you a different level or quality of goods or services
      • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  12. Other California Privacy Rights
    • California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that 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@signifyd.com.
  13. Changes to our Privacy Notice
    • We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.
  14. Contact Information
    1. If you have any questions or comments about this notice, the ways in which we collect and use your personal information as described in this Privacy Notice and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: