CALIFORNIA CONSUMER PRIVACY RIGHTS NOTICE

Effective January 1, 2021


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 for Business Purpose in Preceding 12 Months

CCPA Category

Collected?

Source of Collection

Commercial Purpose

Shared with 3rd Parties?

Purpose of 3rd Party Disclosure

Categories A & B:

Identifiers & Personal Information

Name/Alias

 YES

YOU

Performing Services, Auditing, Data Security, Circa Marketing Communications

Social Network Service (opt-in)

 

Account Registration, Performing Services,  Integrated Services,

Customer Support

Email

YES

YOU

Performing Services, Data Security, Circa Marketing Communications

Service Provider

Performing Services, Integrated Services, Customer Notifications,

Customer Outreach

Address

YES

YOU

Performing Services, Auditing, Data Security

N/A

N/A

Cell or Telephone #

YES

YOU

Performing Services, Auditing, Data Security

Service Provider

Performing Services, Integrated Services

Unique/Online ID (cookies)

YES

YOU / DEVICE

Analytics, Auditing, Data Security

Service Provider

Account Registration, Performing Services,  Integrated Services,

Customer Support

IP Address

YES

DEVICE

Debugging,  Analytics

 

Service Provider (opt-in service)

Account Registration, Performing Services,  Integrated Services,

Customer Support

Account Name/Credentials

YES

YOU

Performing Services,Enabling Opted Integrations,  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

Products/Services

Purchased-Obtained-Considered

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, Weather Alerts

N/A

N/A

Category H:

System data

Audio

Electronic

Visual

Thermal

Olfactory

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

Characteristics

Psychological Trends

Predispositions

Behavior

Attitudes

Intelligence/Abilities/Aptitudes

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.

 

2.     Sale of Personal Information

 

Circa does not sell and will not sell your Personal Information.

 

3.     Your Consumer Rights under CCPA.

 

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

 

A.    Request Circa Disclose At No Charge:

 

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

 

B.    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 NM 87501

C.   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.

D.         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.

 4.  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

 

5.  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.

 

6.   Accessibility of this CCPA Policy.

You can download and print a copy of this Notice at https://www.circa.co/ccpa

 

7.   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, ATTN: Privacy Department, 102 W. San Francisco St, STE 5, Santa Fe Nm 87501