Effective date: January 1, 2020
Last update: January 1, 2020
We have not sold any Personal Information of any consumers in the preceding 12 months.
We collect the following categories of Personal Information:
|Categories of Personal Information (Cal. Civ. Code § 1798.140(o))||Examples of Personal Information that may be collected|
|Identifiers||Name, personal email address, phone number, education, employment, photograph, search history, order history, home address, billing address, credit/debit card information, IP address, email interaction history, social media account information.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, address, telephone number, education, employment, photograph, social media account information, credit card number, debit card number, or any other financial information.|
|Commercial information||Records of products or services purchased, obtained, or considered, or other purchasing history.|
|Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.|
For all categories of Personal Information, we obtain personal information from the following categories of sources:
We may use or disclose the personal information we collect for the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected from you for materially different, unrelated, or incompatible purposes without first providing you notice.
We may disclose your personal information to another party for a business purpose and to the such transfer is strictly required for the purposes mentioned above. We have disclosed personal information to the following categories of parties in the last 12 months:
When legally permitted to do so, we may share personal information with courts, law enforcement authorities, regulators or attorneys if necessary to comply with the law or for the establishment, exercise or defense of legal claims.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the 12 months prior to receiving your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:
We will deny your request to know if (i) we cannot verify your identity; (ii) the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, or the security of our business’s systems or networks. In no event will we disclose your Social Security number, driver’s license number or other government-issued identification number, account password, or security questions and answers.
You have the right to request that we delete some or all of the personal information we have pertaining to you. Once we receive and confirm your verifiable consumer request, we will separately reconfirm your request. After you confirm, we will then delete (and direct our service providers to delete, if applicable) your personal information from our records, unless an exception applies. We may deny your deletion request if we are unable to verify your identity or if we are not required to delete your Personal Information under the CCPA.
To exercise the access, data portability or deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or an authorized agent may make a verifiable consumer related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
We are only required to respond to a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information to allow us to verify you (or an authorized agent) are the person about whom we collected personal information.
We will not 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 use personal information provided in a verifiable consumer request solely to verify the requestor's identity or authority to make the request.
We will acknowledge receipt of your request to know or deletion request within 10 days.
We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period. If you have an account with us, we will deliver our response to the email address for that account. If you do not have an account with us, we will deliver our response by US mail or electronically at the email address in your request, at your option. All 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.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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Postal Address: Dragon Innovation, Inc. | Attention: Privacy Officer | 405 Waltham Street, PMP #228 | Lexington, MA, 02421