California Resident Privacy Notice

Privacy Notice

California Resident Rights

Effective date: June 8, 2023

At CAPE Analytics, we take your privacy seriously. Please read this California Resident Privacy Notice to learn how we treat your Personal Data if you are a California resident. Remember that your use of CAPE Analytics’ Services is at all times subject to our Terms of Use, which incorporates the Privacy Policy for use of our website and/or for use of our Personal and Commercial Lines Web Applications. The website and Personal and Commercial Lines Web Applications policies are collectively referred to in this California Resident Privacy Notice as the “Privacy Policies”. Any terms we use in this California Resident Privacy Notice without defining them have the definitions given to them in the Terms of Use or the Privacy Policies.

If you are a California resident, you have the rights set forth below. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this Notice and any other provision of the Privacy Policies and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@capeanalytics.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

The categories of Personal Data that we have collected about you.
The categories of sources from which that Personal Data was collected.
The business or commercial purpose for collecting or selling your Personal Data.
The categories of third parties with whom we have shared your Personal Data.
The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Personal Data Sharing and Selling Opt-Out and Opt-In

Under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising.

As described in the “Tracking Tools, Advertising and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” or “sharing” of information. You can opt-out of data selling and/or sharing by following instructions in this section.

We have shared and sold the following categories of Personal Data for the purposes of cross-contextual advertising.

Online Identifiers
Device/IP Data
Web Analytics Data

We share and sell Personal Data with the following categories of third parties:

Ad networks
Marketing providers (including for cross-contextual behavioral advertising purposes)

Over the past 12 months, we have shared and sold the following categories of Personal Data with the categories of third parties listed above for the following purposes:

Marketing and selling the Services
Showing you advertisements, including interest-based or online behavioral advertising

You have the right to opt-out of the sharing and selling of your Personal Data. You can opt-out using the following methods:

You can email us at: privacy@capeanalytics.com
You can use a Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale and/or sharing of your Personal Data for at least 12 months.

To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

Sensitive Personal Information

Please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CPRA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Annual Records

The following chart provides statistics about our responses to requests from California residents over the past calendar year:

	Requests to Know	Requests to Delete	Requests to Opt-Out
Requests received:	None.	None.	None.
Requests complied with:	None.	None.	None.
Requests denied:	None.	None.	None.
Median response time (in days):	None.	None.	None.

Exercising Your Rights under CCPA

To exercise the rights described in this Privacy Notice, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, including (i) a combination of your name, job title, email address, and/or company if you are a user of our website or (ii) your login credentials if you are a user of our Personal and/or Commercial Lines Web Application(s), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

Email us at: privacy@capeanalytics.com

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Additional California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@capeanalytics.com.

Contact Information:

If you have any questions or comments about this Notice, the Privacy Policies, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

www.capeanalytics.com
privacy@capeanalytics.com
411 High Street, Palo Alto, CA 94301