Privacy Notice for California Residents which provides further information and describes additional rights arising under the California Consumer Privacy Act (“CCPA”)
This supplemental Privacy Notice describes the rights of California residents under the California Consumer Privacy Act of 2018, which was amended by the California Privacy Rights Act of 2020 (together, “CCPA”). The CCPA requires Antavo to provide certain information to California consumers.
Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our Services or in order to provide our Services (as defined under the Terms of Service), and business-to-business Personal Information.
Any terms defined in the CCPA have the same meaning when used in this Notice.
Antavo LIMITED (company registration nr: 08046168, registered seat: 9th, Floor, 107 Cheapside, London, United Kingdom, EC2V 6DN) (hereinafter referred to as “Antavo”, “We”, “Our”, “Us”) is designing Antavo Academy as an educational programme (“Educational Programme”) to share loyalty knowledge and to develop the next generation of loyalty professionals and business leaders. As one of our trusted partners, we would like to invite you to join us in its creation. Topics we will be looking to cover as part of the study programme will include best practices, case studies, theories, planning and trends in the loyalty industry.
1. Personal information
We collect Personal Information which is defined under the CCPA1.
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.
Personal information does not include publicly available information or lawfully obtained, truthful information that is a matter of public concern.
For purposes of this, publicly available means: information that is lawfully made available from federal, state, or local government records, or information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
Publicly available does not mean biometric information collected by a business about a consumer without the consumer’s knowledge.
Personal information does not include consumer information that is de-identified or aggregate consumer information.
2. Personal Information We Collect
We collected the following categories of personal information:
CCPA Personal Information Category | Collected |
A. Identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers | Yes: real name, email |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) "Personal information" means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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. "Personal information" does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Some personal information included in this category may overlap with other categories. | Yes: name, email, image, position, employer company |
C. 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). | No |
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No |
E. Biometric information Genetic, physiological, behavioral, and biological characteristics. | No |
F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | No |
G. Geolocation data Physical location, approximate location derived from IP address or movements. | No |
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. | |
I. Professional or employment-related information Current or past job history or performance evaluations. | Yes: current position, employer company |
J. 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 maintained by an educational institution. | No |
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes: your participation and your certification |
L. Sensitive Personal Information Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life. | No |
3. Categories of Sources of Personal Information
We collect personal information directly from you.
We obtain the categories of personal information listed above directly from you when you're completing Educational Programmes.
4. Use of Personal Information
Antavo is working on a series of in-depth guides and articles that will be published. We would like to include the opinion of consultants/loyalty experts, like you, who have profound experience in this field.
The answers provided to the Survey will be published on the website of Antavo (https://antavo.com/), and the Linkedin page of Antavo.
The published result of the Survey’s open-ended questions may include your answers given in the form of a quote, together with your image, your name, your position and the company you work at.
Responses given to the multiple choice questions will be published in a fully anonymized form.
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.
5. Disclosures of Personal Information for a Business Purpose
We may disclose Personal Information to a third party for a business purpose.
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. We further restrict the contractor and service provider from selling or sharing your Personal Information.
We disclose the following categories of Personal Information for a business purpose:
| Category (corresponding with the table above) | Category of Recipient | Business Purpose |
1 | Category A Category B Category I Category K Category A Category B Category I Category K
| Google - Cloud computing and storage vendor For further details please refer to the Google privacy policy: https://policies.google.com/privacy | Storage, hosting. |
4 | Own website LinkedIn - social network For details of how your personal data are processed, please refer to the LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy | Marketing which is not cross-context behavioral advertising |
6. Sale or Share of Personal Information
We do not collect personal information for the purpose of selling it in exchange for money.
We do not share Personal Information to a third party for cross-context behavioral advertising.
7. Sensitive Personal Information
We do not collect Sensitive Personal Information.
8. Information Retention
We retain personal information for 3 (three) years.
We retain personal information as long as required to fulfill the purpose defined in Section 4.
9. What are your rights under CCPA?
California Privacy Right | Details |
Right to know what Personal Information is being collected | Antavo shall disclose: (1) The categories of personal information it has collected about consumers. (2) The categories of sources from which the personal information is collected. (3) The business or commercial purpose for collecting, selling, or sharing personal information. (4) The categories of third parties to whom the business discloses personal information. (5) That a consumer has the right to request the specific pieces of personal information the business has collected about that consumer. |
Access Rights | You have the right to request that Antavo that collects personal information about the consumer disclose to you the following: (1) The categories of personal information it has collected about that consumer. (2) The categories of sources from which the personal information is collected. (3) The business or commercial purpose for collecting, selling, or sharing personal information. (4) The categories of third parties to whom the business discloses personal information. (5) The specific pieces of personal information it has collected about that consumer. |
Right to Delete Personal Information | You have the right to request that Antavo delete any personal information about you which Antavo has collected from you. |
Right to Correct Inaccurate Personal Information | You have the right to request Antavo to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. |
Right to Opt Out of Sale or Sharing of Personal Information | You have the right to direct Antavo not to sell or share the consumer’s personal information. |
Right to Limit Use and Disclosure of Sensitive Personal Information | You have the right to direct Antavo to limit its use of your sensitive personal information to purposes defined by law. Antavo does not collect sensitive personal information. |
Right of No Retaliation | Antavo shall not discriminate against you because you exercised any of the consumer’s rights under this title. , |
Data Portability | You can request Antavo to transmit specific pieces of personal information to another entity. The data should be provided in a format easily understandable to the average consumer, and a commonly used, machine-readable format. |
Right to access and opt-out of automated decision making | You may opt-out of automated decision-making, including profiling. Antavo does not make automated decision-making. |
If you wish to exercise any of these rights, please submit a request by emailing us at dpo@antavo.com.
You may exercise these rights free of charge except as otherwise permitted under applicable law. If requests are manifestly unfounded or excessive, in particular because of their repetitive character, Antavo may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify the consumer of the reason for refusing the request.
We may limit our response to your exercise of these privacy rights as permitted under applicable law.
We will respond to a verifiable request within the timeframes set forth under the CCPA, thus, within 45 days of receiving a verifiable consumer request from the consumer. This time period may be extended once by an additional 45 days when reasonably necessary, however, in this case, we will inform you of the extension within the first 45-day period.
We will provide the required information in a readily usable format, if technically feasible, that allows you to transmit this information from one entity to another entity without hindrance.
Antavo may require authentication of you that is reasonable in light of the nature of the personal information requested.
The disclosure of the required information will cover the 12-month period preceding the business’ receipt of the verifiable consumer request.
If Antavo does not take action on your request, it shall inform you, without delay and at the latest within the time period permitted of response by this section, of the reasons for not taking action and any rights you may have to appeal the decision to Antavo.
Please note that, only you or your authorized agent may make a verifiable request related to your personal information. Such requests must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative as well as sufficient details regarding your request that allows us to properly understand, evaluate, and respond to it.
1 Cal. Civ. Code § 1798.140(v)