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California Privacy Notice

Last Modified: April 19, 2024

Purpose

This California Privacy Notice (the “Privacy Notice”) supplements the information contained in the Privacy Policy (“Policy”), located on the LeanTaaS, Inc. (“LeanTaaS,” “we,” or “us”) website (the “Site”), and applies solely to individual residents of the State of California (“consumers,” “residents,” or “you”). This Privacy Notice applies to LeanTaaS, and its affiliates (collectively, “LeanTaaS,” “we,” “us,” or “our”), and describes how we collect, use, disclose, and otherwise process Personal Information of individual residents of the State of California, that we collect (1) from authorized users of web-based software applications that we provide to our business customers (the “Applications”) to the extent we direct the purposes and means of processing of information collected from such authorized users (“Application User Information”) and (2) from users of our website https://leantaas.com/ and any other websites and online services, other than the Applications, that we operate and that include a link to this Policy (collectively, the “Websites”), within the scope of the California Privacy Rights Act (“CPRA”). 

When we use the term “Personal Information” in this Privacy Notice, we mean 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. Any other terms defined in the CPRA have the same meaning when used in this Privacy Notice.

Not included in the definition of Personal Information is information that is publicly available, information that has been de-identified or aggregated, or information exempt from the purview of the CPRA, such as:

  • Protected Health Information (“PHI”) governed and protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
  • Personal Information regulated by certain industry-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

This Privacy Notice does not apply to Personal Information we collected about California residents in their capacity as our job applicant, employee, contractor, or an emergency contact, beneficiary, or dependent of one our applicants, employees, or contractors. Such California Residents should refer to our California Human Resources Privacy Policy for more information.

Additionally, this Privacy Notice applies only to the extent we direct the purposes and means of Personal Information processing and otherwise qualify as a “business” under the CPRA. It does not apply to our activities as a “service provider,” as that term is defined under the CPRA, to our business customers or to Personal Information that we process in that capacity.

Personal Information We Collect

We collect Personal Information from and about you for a variety of purposes. To learn more about the types of Personal Information we collect, the sources from which we collect or receive Personal Information, and the purposes for which we use this information, please refer to the “Information We Collect” section in our Policy.

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Categories
Examples
Collected
Categories of Sources
Identifiers
A real name, Internet Protocol address, email address, or other similar identifiers.
Y
Direct user entry into online forms or through email communications; cookies; pixel tags; and log files.
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.

N
N/A
Protected classification characteristics under California or federal law
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).
N
N/A
Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Y
Cookies; pixel tags; log files and other information obtained through Adobe Marketo.
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.
N
N/A
Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Y
Cookies; pixel tags; log files and other information obtained through analytics technology.
Geolocation data
Physical location or movements.
Y
General location may be derived from your IP addresses.
Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
N
N/A
Professional or employment-related information
Current or past job history or performance evaluations.
N
N/A
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.
N
N/A
Inferences drawn from other Personal Information
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
N
N/A
Purposes for Collection, Use, and Disclosure of Personal Information

Generally, we may collect, use, disclose, transmit, store, and otherwise process the Personal Information about you for one or more of the following purposes: (a) To fulfill or meet the reason you provided the information; (b) Providing, developing, maintaining, personalizing, protecting, and improving the Websites, Applications, and services we offer and provide to you and others, including our business customers; (c) Operating, evaluating, debugging, identifying and repairing errors, effectuating similar functional enhancements, and improving our Websites, Applications, or other services; (d) Understanding how you and our business customers use our Websites, Applications, and other services, performing analytics, analyzing and reporting on usage and performance of the Websites, Applications, and marketing materials, and determining what features and services may interest you and our business customers; (e) To market to you and provide promotional information; (f) Recruitment and hiring purposes, including evaluating and processing your employment application; (g) Storing information about your preferences, recognizing you when you use the Websites, Applications, and customizing your experience; (h) Synchronizing users across devices, affiliates, business partners, business customers, and select third parties; (i) Creating aggregate or deidentified data; (j) Legal and safety purposes, such as maintaining the safety, security, and integrity of our Websites and Applications, other technology assets, services, and our organization, preserving or enforcing our legal rights and property; protecting our users, our employees, and others; and complying with industry standards; (k)  Protecting against malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity; (l) Enforcing our policies, terms of use, contracts, or other legal rights.

We may also use or disclose your Personal Information in accordance with your consent, when required by law to do so, or if it is necessary for a corporate transaction (such as a merger or acquisition). We will not collect additional categories of Personal Information or use the Personal Information for materially different, unrelated, or incompatible purposes without providing you additional notice.

Sharing of Personal Information

In the preceding 12 months, we may have disclosed the categories of Personal Information listed below to the categories of third parties identified below for a business purpose:

  • Identifiers, including online identifiers—with our affiliates, service providers, and as otherwise described in this Privacy Notice.
  • Commercial information—with our affiliates, service providers, and as otherwise described in this Privacy Notice.
  • Internet and other electronic activity information—with our affiliates, service providers, and as otherwise described in this Privacy Notice.
  • Inferences drawn from your activity—with our affiliates, service providers, and as otherwise described in this Privacy Notice.
  • Geolocation data—with our affiliates, service providers, and as otherwise described in this Privacy Notice.
  • Other categories of personal information described in California law—with our affiliates, service providers, and as otherwise described in this Privacy Notice.

We do not disclose Personal Information in exchange for monetary consideration. However, the CPRA defines “sale” very broadly in a manner that includes disclosing Personal Information in exchange for other valuable consideration, including disclosures to third parties for cross-context behavioral advertising purposes in some circumstances (the CPRA also regulates disclosures for cross-context behavioral advertising purposes directly). Under the CPRA, we may sell Personal Information or share Personal Information for cross-context behavioral advertising purposes (which means purposes of displaying advertising to you based on Personal Information obtained or inferred from your activities over time across different websites, applications, and other online services we do not operate), and we may have sold Personal Information or otherwise shared for cross-context behavioral advertising purposes the following categories of Personal Information in the preceding 12 months:

  • Identifiers, including online identifiers.
  • Commercial information.
  • Internet and other electronic activity information.
  • Inferences drawn from your activity.
  • Geolocation data, such as your general location as may be derived from IP addresses.
  • Other categories of personal information described in California law.

We may have shared each of these categories of California Personal Information with third parties such as advertising networks that enable or participate in targeted and cross-context behavioral advertising and/or that provide online tracking technologies that we use to analyze use of the Applications and Websites.

California Rights and Choices

The CPRA provides California residents with certain rights regarding their Personal Information (subject to certain limitations at law). The following section describes your CPRA rights and explains how to exercise those rights.

Right to Access and Portability

Under the CPRA, California residents have the right to request that we disclose certain information about our collection and use of Personal Information over the last twelve (12) months. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will disclose to you the following:

  • 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); and
  • If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

 

Upon receiving a verifiable access request, we will deliver the accompanying information to you in a portable, easily readable electronic format.

Right to Deletion

The CPRA allows California residents the right to request that we delete any Personal Information about you that we collect and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will delete (and in turn direct our service providers to delete, if applicable) your Personal Information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary 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;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Enable solely internal uses that are reasonably aligned with consumer expectations;
  • Comply with a legal obligation and requests from law enforcement agencies; and
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Right to Opt-Out of the Sale or Sharing of Your Information

We do not sell Personal Information for monetary consideration. However, the CPRA defines “sale” very broadly in a manner that includes disclosing Personal Information in exchange for other valuable consideration. Please see the “Sharing of Personal Information” section of this Privacy Notice for more information on disclosures we make that may be considered a “sale” under the CPRA. We do share your information with third parties who assist us in providing you with the services you signed up for. We also share information with third parties who assist us in operating our website and marketing our services. If you request, we will limit or cease sharing information we collect from you as directed. However, if you prevent the sharing of all information collected we may not be able to provide you with the services you have requested.

Right to Limit Use and Disclosure of Sensitive Personal Information

Under the CPRA, with certain limitations, California residents have the right to limit the use of that resident’s sensitive personal information, as that term is defined in the CPRA, to that use which is necessary to perform the requested services or provide the goods requested. Under the CPRA, the following types of information are considered sensitive personal information:

  • A consumer’s social security, driver’s license, state identification card, or passport number;
  • A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
  • A consumer’s precise geolocation;
  • A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
  • The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication;
  • A consumer’s genetic data;
  • Biometric information for the purpose of uniquely identifying a consumer;
  • Personal information collected and analyzed concerning a consumer’s health; or
  • Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

 

Right to Correct Inaccuracies

You may request that we correct Personal Information about you that is inaccurate. We will take into account the nature of the California Personal Information and the purposes of our processing when we address your request.

Request Submissions

To exercise the rights under the CPRA as described above, please submit a verifiable consumer request by calling us at (800) 259.1003, completing this online form or emailing privacy@leantaas.com.   

Verifiable Consumer Requests

A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests for access, which can only be made twice during a twelve (12) month period, limitation, and deletion must:

  • Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
  • 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.

Timeframe for Responding to Requests and Format

We will respond to your request within thirty (30) days of receipt.

The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

Fee

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CPRA prohibits a business from discriminating against California residents for exercising the rights outlined above. We will not discriminate against you for submitting such requests by:

  • Denying goods or services to you;
  • Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
  • Providing a different level or quality of goods or services; and
  • Suggesting a different price or quality of goods or services will apply if rights are exercised.

 

No Financial Incentive

We do not offer any financial incentives or price or service differences in an attempt to influence a resident’s decision whether or not to exercise a right afforded to the consumer under the CPRA.   

Children’s Information

Our Applications and Websites are not directed at children. We do not knowingly collect or sell Personal Information from children under the age of 16. We do not knowingly share the Personal Information of children under the age of 16 for cross-context behavioral advertising purposes. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Contacting Us” section, below, and we will take steps to remove such Personal Information from our systems.

Authorized Agent

A California resident may use an authorized agent to submit a right to access request or a request to delete. To use an authorized agent, the California resident must provide the agent with written authorization. In addition, the California resident may be required to verify their own identity with us. LeanTaaS may deny a request from an agent that does not submit proof that they have been authorized by the California resident to act on their behalf. Such requirements, however, will not apply where a California resident has provided the authorized agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

Updates to this Privacy Notice

We may update or change this Privacy Notice. The effective date at the top of this page states when this Privacy Notice was last revised. Any change to this Privacy Notice will become effective when we post the revised Privacy Notice on our Site. Your use of our Site means you accept our Privacy Notice.

If any change may materially and negatively affect the privacy of your Personal Information, we will use reasonable efforts to notify you in advance and give you a reasonable time to object to any changes.

We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share Personal Information.

Contacting Us

Use the contact information below if you have questions, concerns or complaints about this Privacy Notice or our privacy practices or would like additional information about LeanTaaS’ privacy practices.

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