California Consumer Privacy Rights Notice

Effective: January 1, 2020

This California Consumer Privacy Rights Notice (“Notice”) sets forth EventGeek, Inc. dba Circa’s disclosure obligations under California law, including the California Consumer Privacy Act of 2018 (“CCPA”) and California Civil Code section 1798.83. This Notice provides additional details regarding the information defined as ‘personal information’ under applicable California law and related to a California resident or household (“Consumers” and “You”) further referred to as “Personal Information.”

  1. Personal Information Collected and Disclosed:

Circa collects, uses and/or discloses Personal Information as follows:

Personal Information Collected, Used and/or Disclosed in Preceding 12 Months

CCPA Category

Collected?

Source of Collection

Business Purpose

Disclosed or Shared for a Business Purpose?

Purpose  of Disclosure

Category A Identifiers & B Personal Information

  • Name/Alias

YES

YOU

  • Performing Services
  • Auditing
  • Data Security
  • Circa Service and marketing communications

Social Network Service (opt-in)

Account Registration

Performing Services; Integrated Services;

customer support;

  • Email

YES

YOU

  • Performing Services
  • Data Security
  • Circa Service or Marketing Communications

Service Provider

Performing Services; Integrated Services; Customer notifications;

Customer outreach

  • Address

YES

YOU

  • Performing Services
  • Data Security
  • Auditing

N/A

N/A

  • Cell or Telephone #

YES

YOU

  • Performing Services
  • Data Security

Service Provider

Performing Services;

Integrated Services

  • Unique/Online ID (cookies)

YES

YOU;

DEVICE

  • Analytics
  • Auditing
  • Data Security

Service Provider

Performing Services; Integrated Services; Support and Circa communications

  • IP Address

YES

DEVICE

  • Debugging
  • Analytics

Service Provider (opt-in service)

Performing Services; Integrated Services; Customer Support

  • Account Name/Credentials

YES

YOU

  • Performing Services
  • Data Security

Service Provider (opt-in)

Performing Services; Integrated Services CRM

  • Social Security #

NO

N/A

N/A

N/A

N/A

  • Driver’s License#

NO

N/A

N/A

N/A

N/A

  • Passport #

NO

N/A

N/A

N/A

N/A

  • Credit or Debit Card # /ACH

YES*

*Token only

YOU

  • Performing Services

Service Provider

Performing Services; Integrated Services; Process Payment

  • Other: Medical/Financial/Health

NO

N/A

N/A

N/A

N/A

Category C: Protected Characteristics

NO

N/A

N/A

N/A

N/A

Category D: Commercial Information

  • Personal Property Records

NO

N/A

N/A

N/A

N/A

  • Products/Services Purchased-Obtained-Considered

NO

N/A

N/A

N/A

N/A

  • Purchasing history/tendencies

NO

N/A

N/A

N/A

N/A

Category E: Biometric Information

NO

N/A

N/A

N/A

N/A

Category F: Internet/Network Activity

  • Browsing/search history
  • Interaction with site/advertisement

YES

YOU;

Device

  • Analytics*

Opt-out available

Service Provider

  • Analytics

Category G: Geolocation data

YES

YOU;

Device

  • Performing Services: Event Data

N/A

N/A

Category H:

  • Audio

NO

N/A

N/A

N/A

N/A

  • Electronic

NO

N/A

N/A

N/A

N/A

  • Visual

NO

N/A

N/A

N/A

N/A

  • Thermal

NO

N/A

N/A

N/A

N/A

  • Olfactory

NO

N/A

N/A

N/A

N/A

  • Other Similar

NO

N/A

N/A

N/A

N/A

Category L: Professional/Employment-Related

NO

N/A

N/A

N/A

N/A

Category J: Educational Information

NO

N/A

N/A

N/A

N/A

Category K: Inferences from Data Collected

  • Preferences

NO

N/A

N/A

N/A

N/A

  • Characteristics

NO

N/A

N/A

N/A

N/A

  • Psychological Trends

NO

N/A

N/A

N/A

N/A

  • Predispositions

NO

N/A

N/A

N/A

N/A

  • Behavior

NO

N/A

N/A

N/A

N/A

  • Attitudes

NO

N/A

N/A

N/A

N/A

  • Intelligence/Abilities/Aptitude

NO

N/A

N/A

N/A

N/A

Other Potential Third Party Disclosures:  Personal Information may also be disclosed to third parties to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) as part of a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all or part of the business, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies as required by law; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations.

  1. Sale of Personal Information

Cookies, Web Beacons, IP Addresses.  The Platform has collected and shared certain unique/online Identifiers, such as cookies, with our advertising partners. Such sharing may constitute a “sale” under the CCPA, which broadens the definition of “sale” and “personal information” beyond how you might commonly interpret those terms.  Under the CCPA, “personal information” includes information that is not necessarily directly tied to an individual’s identity but may be associated with a device. This includes identifiers such as IP addresses, web cookies, web beacons.  Similarly, the term “sell” is defined to include not just selling in exchange for money, but also sharing or transferring personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which is not limited to the exchange of money.   In the last 12 months, Company has shared data with advertising partners, to delivering relevant advertising to you.  When you opt out  under this Section, Company will stop sharing your information with those of its advertising partners with whom such sharing is considered a “sale” under the CCPA.  If you do not allow these cookies, you will experience less targeted advertising.  

Publicly-Sourced Information.   In the last 12 months, the Circa Intel Chrome Extension has collected and shared certain publicly-sourced personal information from B2B industry events, including the names, job titles, employer name, business phone and email, and social networking urls of event hosts, organizers, sponsors, speakers and other event-related contacts, with subscribers to the Circa Intel Services.  

Please see Section 3.C to exercise your opt-out rights.

  1. Your Consumer Rights under CCPA.

California Consumers may contact Circa through their account, by email at privacy@circa.co or through this webform.

  1.  Request Circa Disclose At No Charge:

Right to Know Requests can be submitted to Circa by email at privacy@circa.co

  1. Request Circa to Delete At No Charge:

Except as exempted pursuant to CCPA 1798.105, to request Circa delete Personal Information.

Deletion Requests can be submitted to Circa be email at privacy@circa.co or by mail to Circa at:  102 W San Francisco St, STE 5, SANTA FE, NEW MEXICO 87501

  1. Right to Opt-Out  - Do Not Sell My Personal Information

You have the right to opt out of the sale of Personal Information as that term is defined by the CCPA.  You may do so through either of the following methods:

  1. Submit a request through our Do Not Sell My Personal Information Web Form.
  2. Email privacy@circa.co with a subject heading “Do Not Sell My Personal Information

  1.  Verified Request Process

CIRCA will verify all consumer requests prior to taking any action in response to such request.  For consumers that maintain an account with CIRCA, it may verify the identity of the consumer making the request by either matching with the account information on file or through existing account authentication credentials.  For non-account holders, Circa shall verify to a reasonably high degree of certainty, including matching at least three pieces of consumer personal information with that maintained by Circa and/or if necessary, by a signed statement by consumer under penalty of perjury that the requestor is the consumer for which personal information is sought.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf.  Authorized agents must demonstrate they have written authorization from you to make requests on your behalf. Circa may additionally require the consumer to confirm their identity and verify the authorized agent’s permission before complying with any request.

  1. Consumer Request Limitations  

Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA, including, but not limited to:

Circa will confirm and respond to all requests within the timeframe required under the CCPA.  In responding to any request to disclose/delete, Circa shall maintain a record of the requests as required under the CCPA.

  1. Non-Discrimination Policy

You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA.   Circa shall not discriminate against a consumer for exercising any rights under the CCPA, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates (including discounts/penalties) that is not directly related to the value provided to Circa for the Personal Information, (c) suggesting Consumer will receive a different rate/price or different level of quality of goods/services

  1. Your California Privacy Rights under California Civil Code Section 1798.83 & Business and Professions Code Section 22581

California law permits Consumers to request and obtain from once a year, free of charge, certain information about their Personally Identifiable Information (“PII”) (as defined by California law) disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of PII that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.

In addition, a business subject to California Business and Professions Code Section 22581 must allow California residents under age 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

  1. Accessibility of this CCPA Policy.

  1. Contact Us

Additional detail regarding our collection, use and disclosure of Personal Information, as well as general opt-out rights and other privacy disclosures, is set forth in our general Privacy Policy.

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: Circa, Inc., Attention: Privacy Department, 102 W SAN FRANCISCO ST, STE 5, SANTA FE, NEW MEXICO 87501 or by email at privacy@circa.co 

This Notice was last updated: December 13, 2021