Notice to California Residents
Personal Information of Employees Collected, Used, and Shared in the Past 12 Months
Set out below is a table that contains information about the Personal Information we have collected, processed, and shared in the preceding twelve (12) months. This will be updated annually in accordance with relevant data protection laws.
|Categories of Personal Information||Examples of Personal Information||Categories of Third-Party Entities with whom the Personal Information is Shared|
|Identifiers||Name, date of birth, address, telephone numbers, personal email addresses, SNS account (if registered for campaigns via SNS), and other unique identifiers such as your device IDs.||Group Entities, Contractors, and Service Providers.|
|Personal Information Categories Described in the California Customer Records Statute||Credit card or debit card number and bank account information.||Group Entities, Contractors, and Service Providers.|
|Commercial Information||Billed amounts, paid amounts, payment methods, and other information relating to fee payments and transaction histories.||Group Entities, Contractors, and Service Providers.|
|Geolocation data||IP address and location information about your devices.||Group Entities, Contractors, and Service Providers.|
|Inferences drawn from any of the information identified in this table to create a profile about a consumer reflecting the consumer’s preferences||Group Entities, Contractors, and Service Providers.|
For purposes of this Notice, “Group Entities” refers to the subsidiaries, affiliates, and related companies of Soracom Global, Inc.
“Contractors” refers to a person to whom the business makes available a consumer’s personal information for a business purpose pursuant to a written contract.
“Service Provider” refers to a person that processes personal information on behalf of a business and that receives from or on behalf of the business a consumer’s personal information for a business purpose pursuant to a written contract.
We Do Not Sell Your Personal Information
If in the future we anticipate the need for sale of your Personal Information to a Third Party, we will provide you with the opt-out rights as required by law. A “Third Party” is defined as an entity that is not (i) the business with whom the consumer intentionally interacts and that collects Personal iInformation from the consumer as part of the consumer’s current interaction with the business”, (ii) a Service Provider to the business, or (iii) a Contractor.
For purposes of this Notice, “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
The CCPA and CPRA secures the following rights for California residents, discussed in more detail below:
- The right to know about the personal information a business collects about them and how it is used and shared;
- The right to delete personal information collected from them (with some exceptions);
- The right to rectify and correct any inaccurate information collected from them;
- The right to restrict or limit the use and disclosure of sensitive personal information;
- The right to opt-out of the sale and sharing of their personal information; and
- The right to non-discrimination for exercising their CCPA and CPRA rights.
Right to Know
You may request that we disclose to you certain information about the Personal Information we have collected, used, shared, or sold about you in the preceding twelve (12) months. Specifically, you may request that we disclose the categories and specific pieces of Personal Information collected, the categories of sources from which the business collected Personal Information, the purposes for which the business uses the Personal Information, and the categories of Third Parties with whom the business shares the Personal Information.
You may make a request for such disclosure, free of charge, twice per year. The information may be delivered electronically and will be in a portable and, to the extent technically feasible, readily usable format that allows you to transmit this information to another entity.
Right to Delete
You may request that we delete Personal Information we collected from you, subject to the exemptions in CCPA §1798.105. Once we confirm your verifiable request, we will delete (and direct our Group Entities, Contractors, and Service Providers to delete) your Personal Information from our records.
Right to Rectify
You may request that we correct any inaccurate Personal Information we hold about you. Upon verifying your request, taking into account the nature of the Personal Information and purposes of processing such Personal Information, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
Right to Limit the Use and Disclosure of Sensitive Personal Information
Under the CPRA, you have the right to request that we limit the use and disclosure of your sensitive Personal Information, subject to the exemptions in CPRA §1798.121. Sensitive Personal Information includes, but is not limited to, your account login, credit card or debit card number, and precise geo-location. For more information, please see CPRA §1798.40(ae).
Right to Opt-Out of Sale
You may request a business to stop selling your Personal Information (“opt-out”). As explained above, we do not sell Personal Information.
Right to Opt-Out of Personal Information-Sharing
Under the CPRA, the right to opt-out is extended to the right to opt-out of the sharing of Personal Information with Third Parties for the purposes of cross-context behavioral advertising. If you wish to opt-out of the sharing of your Personal Information, please fill out the form or follow the instructions on the Do Not Sell Or Share My Personal Information page.
Right to Non-Discrimination
The CCPA and CPRA prohibit businesses from discriminating against a California resident for exercising any of their rights under the CCPA or CPRA. Forms of discrimination include denying goods or services, charging different prices or rates for goods or services (including through the use of discounts or other benefits or by imposing penalties), providing a different quality of goods or services, and suggesting that the person exercising their rights will receive a different price or quality of goods or services.
How To Make a Request
To opt-out of the sharing of your Personal Information, please go to our Do Not Sell Or Share My Personal Information page and follow the instructions.
If you wish to make any other request regarding your Personal Information, please go to our Contact Soracom page or email us at firstname.lastname@example.org.
Please note that we may refuse to comply with your request, in which case we will provide you with our reasons. We may also request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
Changes to this Notice
We reserve the right to update this Notice at any time, and we will update the Notice with the “Last Reviewed On” date.