Ponto Software, Inc. California Resident Privacy Notice
Last Reviewed and Updated: 10/06/2022
This California Resident Privacy Notice (“Notice”) supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.
This Notice does not apply to nonpublic personal information collected from California residents pursuant to the Gramm-Leach Bliley Act (“GLBA”). For example, this Notice does not apply to California residents who utilize financial products or services offered by us for personal, family, or household purposes. For additional information with respect to how we collect, disclose, and secure information relating to these customers, please refer to our U.S. Consumer Privacy Notice here.
Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, 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, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA, such as information collected pursuant to the GLBA.
The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
Use of Personal Information
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
1. Providing Services: Providing our services.
2. Communicating: Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing customer support.
3. Personalization: Personalizing your experience on our services, such as presenting tailored content. 4. Sending Messages: Sending you text messages or push notifications.
5. Facilitating Payments: Facilitating transactions and payments.
6. De-identification and Aggregation: De-identifying and aggregating information collected through our services and using it for lawful purposes.
7. Job Applications: Processing your job application.
8. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
9. Auditing Interactions: Auditing related to your interaction with our services and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with other standards.
10. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
11. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
12. Contracting Vendors: Contracting with vendors and service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing.
13. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
14. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
15. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.
Collection of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
1. You/Your Devices: You or your devices directly.
2. Users: Other users of our services.
3. Affiliates.
4. ISPs: Internet service providers.
5. Analytics Providers.
6. OS/Platform Provider: Operating systems and platforms.
7. Social Networks.
8. Resellers: Consumer data brokers.
9. Partners: Business partners and our corporate clients.
10. Public: Publicly accessible sources.
Disclosure of Personal Information
In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties:
- I. ISPs: Internet service providers.
- Personal Information we share: Identifiers and Internet or Other Electronic Network Activity.
- II. Analytics Providers.
- Personal Information we share: Identifiers, Commercial Information, Internet or Other Electronic Network Activity.
- III. Vendors: Vendors and service providers
- Personal Information we share: Identifiers, Commercial Information, and Internet or Other Electronic Network Activity.
- IV. Third Parties as Legally Required: Third parties as required by law and similar disclosures
- Personal Information we share: Identifiers and Internet or Other Electronic Network Activity.
Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations
Right to Opt Out. We do not sell your Personal Information.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Submit Requests. To exercise your rights under the CCPA, please write to us by email or mail via the information provided in the Contact Information section.
Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please provide a written authorization signed by the resident, and we will contact you and the resident with further steps required to verify the resident’s identity.
Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
Contact Information
If you have any questions, comments, or concerns about this notice or our processing activities please write to us by email at support@ponto.org or by mail at Ponto Software Company, Inc., 155 Montgomery Street, Suite 700, San Francisco, CA 94104.