Effective date: June 5, 2020
This PRIVACY NOTICE & POLICY FOR CALIFORNIA RESIDENTS is provided by the Slate Group LLC (collectively, “Slate,” “we,” “us,” or “our”) and applies solely to residents of the State of California (“consumers” or “you”).
California Consumer Privacy Act (“CCPA”)
Any terms defined in the CCPA and the proposed regulations have the same meaning when used in this disclosure.
Information We Collect
We collect offline and online personal information. Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We collect the following categories of personal information:
• We collect your name, telephone number, email address, postal address, user name, display name, self-selected avatar, and password when you create an account or contact us via our Services. We use this information to provide our services, respond to your requests, and send information and advertisements to you.
• We collect your social media handle and basic account information when you interact with our services through social media such as Facebook, and Twitter. We use this information to improve our services, respond to your requests or complaints, and send information and advertisements to you.
• We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our services in order to identify you, provide our Services, prevent fraud, and provide you with targeted advertising and offers.
• We collect your payment information, such as credit card number and expiration date, when you provide it to us, or to a service provider working on our behalf, when you complete a transaction. We use this information to facilitate payments and transactions.
• We do not collect your Driver’s License number or passport number.
• We do not collect your social security number.
• We collect or infer your disability status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions). We do not otherwise collect your medical information or health information.
• We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.
• We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, to identify you, and to provide you with targeted information and offers.
Protected Classification Characteristics Under California or Federal Law:
• We collect or infer your age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, disability status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status when you interact with our websites or mobile apps.
• We use this information to carry out our obligations and enforce our rights arising from any contracts entered between you and us, and to better understand the makeup of our audience and provide aggregate statistics on our audience to partners.
• When you engage in transactions with us, we create records of personal property, products, or services purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.
• We collect this information from you, from your devices when you interact with our websites or mobile apps, and from Slate employees when you interact with them and provide Personal Information.
• We use this information to carry out our obligations and enforce our rights arising from any contracts entered between you and us for products or services purchased and to provide you with information, products, or services that you request from us. We also use this information to measure the effectiveness of our Services, to improve the content we produce and products we recommend, and to provide you with targeted information, advertisements, and offers.
Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.
Internet or Other Electronic Network Activity Information:
• We collect information about your browsing history, search history, and information regarding your interaction with websites, applications, or advertisements automatically when you utilize our Services.
• We use this information to help maintain the safety, security, and integrity of our website, services, databases and other technology assets, used to support our business, and for testing, research, analysis, and product development, including to develop and improve our website and services.
• As described above, we collect your precise geolocation from GPS-enabled devices and from you when you provide Slate with this information via a survey. As described above, we collect your IP address automatically when you visit our sites. We may be able to determine your general location based on your IP address.
• We use this information to understand the geographic distribution of our users and to enable location based advertising.
Audio, electronic, visual, thermal, olfactory, or similar information:
• We may collect visual information in the form of photos and videos taken at Slate events.
Professional or employment-related information:
• We collect or infer information about your professional memberships, certifications, licenses or credentials, such as when you provide Slate with this information via a survey.
• We use this information to understand our users and to provide this information to advertisers (e.g., segments of users in specific roles such as “c-suite”).
• We collect or infer your educational information, such as when you provide Slate with this information via a survey.
• We use this information to understand our users and provide advertisers with segments of users with specific backgrounds (e.g. “well educated”).
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics:
• We analyze your actual or likely preferences through a series of processes and add our observations to your internal profile. We use this information to help us better understand our users and the content they want to consume; to build segments for targeted advertisements; to gauge and develop our marketing activities; to measure the appeal and effectiveness of our services, applications, and tools; and to provide you with targeted information, advertisements, and offers.
On certain occasions, we sell information to third parties. An external party may be considered a third party either because the purpose of sharing the Personal Information is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit. We sell the following information:
• Personal Identifiers: We provide your IP address and Device ID to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.
• Commercial Information: We provide information about your commercial transactions with us to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.
• Internet or Other Electronic Network Activity Information: We provide information about your Internet or other electronic network activity information to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.
• Geolocation Data: We provide information about your geolocation to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.
• Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.
Sharing Personal Information
We disclose your personal information to service providers who perform services and functions on our behalf. When we disclose personal information to our service providers, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except for fulfilling requirements and services being performed under contract.
You have the right at any time to direct us not to sell your personal information and opt-out by clicking on the “Do Not Sell My Personal Information” link, which is located in the footer of our pages and at https://slate.com/do-not-sell. Over the past 12 months we have “sold” personal information within the above listed categories to the following categories of entities:
• Co-marketing partners
• Advertising platforms
• Social media platforms
• Analytics providers
• Marketing companies
We will not sell personal information of minors under 18 years of age without affirmative authorization.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes those rights.
Request to Access Your Personal Information
You have the right to request access to personal information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ personal information, we are required to verify your identity before we can act on your request.
As part of our verification process of your request we ensure reasonable measures are in place to detect fraudulent requests and prevent unauthorized access to your personal information. We are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent by associating the information provided in the request to any personal information previously collected by us or use a third-party identity verification service.
We will disclose the following information to you upon receiving your verifiable request:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• Specific pieces of personal information we collected about you.
• Our business or commercial purpose for selling or disclosing the personal information, if applicable.
Requests to Delete Your Personal Information (Right to Request Deletion)
You have the right to request in certain circumstances that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. You may submit such a request as described below. To protect our customers’ personal information, we are required to verify your identify before we can act on your request. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Submitting Request to Know or Delete
To exercise the rights described above, you can contact us by submitting your request by:
Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.
In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.
If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.
We are not required to provide personal information to you more than twice within a 12-month period.
We will not require you to create an account with us in order to make a request. We will only use personal information provided in a request to verify your identity or authority to make the request.
Right to Opt Out of the Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information to third parties.
To exercise this right, please visit our “Do Not Sell My Personal Information” webpage. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
“Shine the Light Law”
We do not provide your personal information to third parties for their use in direct marketing.
Changes to this Privacy Notice and Policy
We reserve the right to amend this privacy notice and policy at our discretion and at any time. When we make changes to this privacy notice and policy, we will notify you through a notice on our website homepage.
Obtaining this Notice in an Alternative Format
You may obtain this notice in an alternative format by contacting us at firstname.lastname@example.org.
If you have any questions or comments about this Privacy Notice & Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, if you wish to exercise your rights under California law, or if you need this disclosure in another format, please do not hesitate to contact us at email@example.com.