Effective Date: January 1, 2023
This Privacy Notice for California Residents supplements the information
contained in Tot Squad’s Privacy Policy and applies solely to all visitors, users,
and others who reside in the State of California ("consumers" or "you"). We adopt
this notice to comply with the California Consumer Privacy Act of 2018 (CCPA)
and as amended and effective January 1, 2023, the California Privacy Rights Act
(CPRA). Any terms defined in the CCPA and CPRA have the same meaning
when used in this Notice. The CCPA and CPRA are collectively referred to as
the “CCPA” for purposes of this Notice.
For information collected for our California-based employees, job applicants,
contractors, or similar individuals please see the section at the end of this Notice
entitled “CCPA Notice at Collection for California Employees and Applicants”.
Where noted below, certain exemptions apply for personal information collected
through a written or verbal business-to-business communication ("B2B personal
information") from some its requirements.
Information We Collect
We collect 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, household, or device ("personal
information").
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
Health or medical information covered by the Health Insurance Portability andAccountability Act of 1996 (HIPAA) and the California Confidentiality of Medical
Information Act (CMIA) or clinical trial data;
Personal information covered by certain sector-specific privacy laws, including
the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or
California Financial Information Privacy Act (FIPA), and the Driver's Privacy
Protection Act of 1994.
In particular, we have collected the following categories of personal information
from its consumers within the last twelve (12) months:
Highly Sensitive Information
Certain of the categories listed above represent “Highly Sensitive Information” as
such term is defined in the CPRA. We do not collect, use, share or store Highly
Sensitive Information except for purposes of performing our services, providing
our products or for such purposes as requested by you. For example, we may
collect Highly Sensitive Information such as credit card or financial information for
purposes of a transaction involving our products or services. We may also use
Highly Sensitive Information to conduct background checks or for other purposes
authorized by yourself. We do not share Highly Sensitive Information with third
parties unless they are necessary to assist us in performing the services
requested. For example, we may share Highly Sensitive Information with
payment processors to conduct transactions or with third-party vendors who
assist us with performing background checks if required. We do not sell Highly
Sensitive Information to any third-parties. We also may collect Highly Sensitive
Information in an employment context if you are applying for a position with our
company or are currently or formerly employed by our company. For more
information regarding our Highly Sensitive Information in an employment context
please see below “CCPA Notice at Collection for California Employees and
Applicants”.
Retention Periods for Highly Sensitive Information
Pursuant to the requirements of the CPRA [Specifically, Cal. Civ. Code §
1798.100(a)(3)], we would like to inform you that we will only keep personal
information and Highly Sensitive Information for so long as it is reasonably
necessary to do so in accordance with the provisions of the CPRA and our
internal policies. If you are concerned regarding our retention of your personal
information including Highly Sensitive Information you may request deletion of
such information in accordance with the provisions of this Notice in the manner
set forth below. We may be required by law to retain certain information
including your personal information and Highly Sensitive Information in
accordance with applicable laws requiring us to maintain such information or for
a legitimate business purpose to maintain such information including but not
limited to prevent fraud or to enforce our policies.
B2B Information
We currently collect certain business to business (B2B) information from
vendors, customers, service providers and suppliers in order to conduct our
business. This information usually includes e-mail addresses, business
addresses, phone numbers, tax information such as EIN and may include Highly
Sensitive Information such as credit cards or financial bank information such asaccount numbers. We do not share this information with third-parties except to
perform services or transactions requested by our B2B contacts.
We obtain the categories of personal information listed above from the following
categories of sources:
Directly from you. For example, from forms you complete or products and
services you purchase.
Indirectly from you. For example, from observing your actions on our Website.
When we provide services or products to you after obtaining your consent.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more
of the following purposes:
To fulfill or meet the reason you provided the information. For example, if you
share your name and contact information to request a price quote or ask a
question about our products or services, we will use that personal information to
respond to your inquiry. If you provide your personal information to purchase a
product or service, we will use that information to process your payment and
facilitate delivery. We may also save your information to facilitate new product
orders or process returns.
To provide, support, personalize, and develop our Website, products, and
services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent
transactional fraud.
To provide you with support and to respond to your inquiries, including to
investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and
service offerings relevant to your interests, including targeted offers and ads
through our Website, third-party sites, and via email or text message (with your
consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and
services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop
and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court
order, or governmental regulations. As described to you when collecting your
personal information or as otherwise set forth in the CCPA. If you consent to our
sharing personal information for purposes of offering other services or products
or promotions to you.
To evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of our assets, whether as a
going concern or as part of bankruptcy, liquidation, or similar proceeding, in
which personal information held by us about our users is among the assets
transferred.
We will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.
Sharing Personal Information
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). When we
disclose personal information for a business purpose, we enter a contract that
describes the purpose and requires the recipient to both keep that personal
information confidential and not use it for any purpose except performing the
contract. The CCPA prohibits third parties who purchase the personal information
we hold from reselling it unless you have received explicit notice and an
opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
Service providers;
Promotions partners that offer services or products that you may be interested in.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following
categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.
Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following
categories of third parties:
Service providers.
Promotions partners that offer services or products that you may be interested in.
Sales of Personal Information
In the preceding twelve (12) months, may sell or has sold the following
categories of personal information:
A. Identifiers.
K. Inferences drawn from other personal information.
We may sell your personal information to the following categories of third parties:
Promotions partners that offer services or products that you may be interested in.
Your Rights and Choices
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.
Access to Specific Information and Data Portability Rights
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.
We do not provide these access and data portability rights for B2B personal
information.
Deletion Request Rights
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:
1. 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, fulfill the terms
of a written warranty or product recall conducted in accordance with federal law,
or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended
functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their
free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal
Code § 1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer
expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with
the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
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:
Calling us at (877) 700-8612
Submitting an online form at: https://ccpaverification.com/tot-squad/
Only you, or someone legally authorized 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. To designate
an authorized agent your agent will need to contact us HERE and provide
verification of their identity along with your email so that we may confirm that you
have authorized the agent to act on your behalf.
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 an authorized
representative, which may include:
Your name, email address, zip code and primary phone number through the
online form:
https://ccpaverification.com/tot-squad/ or by leaving a voicemail at (877) 700-
8612.
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. We will only use personal
information provided in a verifiable consumer request to verify the requestor's
identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales
Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time (up to 45 days), we will inform you of
the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding 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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 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 at least 13 but not yet 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 email address: HERE
Once you make an opt-out request, we will wait at least twelve (12) months
before asking you to reauthorize personal information sales. However, you may
change your mind and opt back in to personal information sales at any time by
sending an email to HERE.
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.
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.
However, we may offer you certain financial incentives permitted by the CCPA
that can result in different prices, rates, or quality levels. Any CCPA-permitted
financial incentive we offer will reasonably relate to your personal information's
value and contain written terms that describe the program's material aspects.
Participation in a financial incentive program requires your prior opt in consent,
which you may revoke at any time.
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 HERE.
CCPA Notice at Collection for California Employees and Applicants
We collect and uses Personal Information for human resources, employment,
benefits administration, health and safety, and business-related purposes and to
be in legal compliance. Below are the categories of Personal Information we
collect and the purposes for which we intend to use this information:
· Identifying information, such as your full name, gender, date of birth, and
signature.
· Demographic data, such as race, ethnic origin, marital status, disability,
and veteran or military status.
· Contact information, such as your home address, telephone numbers,
email addresses, and emergency contact information.· Dependent's or other individual's information, such as their full name,
address, date of birth, and Social Security numbers (SSN).
· National identifiers, such as SSN, passport and visa information, and
immigration status and documentation.
· Educational and professional background, such as your work history,
academic and professional qualifications, educational records, references,
and interview notes.
· Employment details, such as your job title, position, hire dates,
compensation, performance and disciplinary records, and vacation and
sick leave records.
· Financial information, such as banking details, tax information, payroll
information, and withholdings.
· Health and Safety information, such as health conditions (if relevant to
your employment), job restrictions, workplace illness and injury
information, and health insurance policy information.
· Information Systems (IS) information, such as your search history,
browsing history, login information, and IP addresses on the Company's
information systems and networks.
· Sensory or surveillance information, such as COVID-19 related
temperature checks and call monitoring and video surveillance.
· Profile or summary about an applicant/employee's preferences,
characteristics, attitudes, intelligence, abilities, and aptitudes.The Company collects Personal Information to use or disclose as appropriate to:
· Comply with all applicable laws and regulations.
· Recruit and evaluate job applicants and candidates for employment.
· Conduct background checks.
· Manage your employment relationship with us, including for:
· onboarding processes;
· timekeeping, payroll, and expense report administration;
· employee benefits administration;
· employee training and development requirements;
· the creation, maintenance, and security of your online employee
accounts;· reaching your emergency contacts when needed, such as when you
are not reachable or are injured or ill;
· workers' compensation claims management;
· employee job performance, including goals and performance reviews,
promotions, discipline, and termination; and
· other human resources purposes.
· Manage and monitor employee access to company facilities, equipment,
and systems.
· Conduct internal audits and workplace investigations.
· Investigate and enforce compliance with and potential breaches of
Company policies and procedures.
· Engage in corporate transactions requiring review of employee records,
such as for evaluating potential mergers and acquisitions of the Company.
· Maintain commercial insurance policies and coverages, including for
workers' compensation and other liability insurance.
· Perform workforce analytics, data analytics, and benchmarking.
· Administer and maintain the Company's operations, including for safety
purposes.
· For client marketing purposes.
· Exercise or defend the legal rights of the Company and its employees.
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. Your continued
use of our Website following the posting of changes constitutes your
acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which Tot
Squad collects and uses your information described here and in the 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:
Phone: (310) 895-9983
Website: www.totsquad.com
Email: HERE
Postal Address: Tot Squad Attn: Support Address: 13950 Ventura Blvd,
Sherman Oaks, CA 91423
