Effective Date: 09/15/2021

This California Consumer Privacy Act (“CCPA”) Notice (“CCPA Notice”) is incorporated into KeyLogic’s general privacy policy available here and applies to the personal information of California residents using our website and services (“Consumers,” “you,” or “your”).  For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

In the event of a conflict between this CCPA Notice and any of our other privacy policies, this CCPA Notice shall control only with respect to Consumers and their personal information. 

Your Rights

Verified California residents have the right to:

• request and receive disclosure of our Information Collection Practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
• request and receive disclosure of our Information Sharing Practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
• request and receive a copy of the specific personal information we have collected about them during the prior 12 months.
• request that we not sell personal information about them and
• request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

The CCPA rights described above do not apply to information collected in the employment context about our current, former or prospective employees or contractors (who receive separate disclosures under the CCPA) or to information collected about California business contacts (employees, owners, directors, officers, or contractors of companies, sole proprietorships, and other entities collected in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such companies, sole proprietorships, or entities).  California business contacts have the right to tell us not to sell their information; please see below for how to exercise this right.

Exercising Your Rights

In order to make a request for disclosure California residents may contact us by calling us at 1-888-204-9649 or by sending an email to privacy@keylogic.com.  We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) including your full name, residence address, telephone number, email address and relationship to KeyLogic and will use that information only for that purpose. If you request specific information collected about you or deletion of information we may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be.  We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 business days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

You may make a request for disclosure of our Information Collection Practices, the specific information we collected about you, or our Information Sharing Practices up to twice within a 12-month period.  You may make a request that we not sell information or for deletion of your information at any time.

For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances.  By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.

We will not discriminate against you as a result of your exercise of any of these rights. 

Selling Information.  – We do not sell your information for monetary consideration and we do not disclose your information for other valuable consideration.  If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this privacy policy and our compliance with the CCPA.

We do not sell you information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CCPA. During the past 12 months we disclosed [Identifiers, Electronic Network Activity – list any other categories ] with third parties such as advertising and analytics providers [ any others?] for a business purpose which falls within the definition of a ‘sale’.  If you are a California resident over the age of 16 and would like to instruct us not to sell your personal information, please visit our Do-Not-Sell web page here.  We do not sell personal information of individuals we actually know are less than 16 years of age. Once we receive your Do-Not-Sell request we will wait at least 12 months before asking you to reauthorize personal information sales.

Using an Authorized Agent.  You may submit a request through someone holding a formal Power of Attorney.  Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized.  We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Information Collected

During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties.  The categories of information include information we collect from our website visitors, customers, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals.  For instance, we may collect different information from applicants for employment or from vendors or from customers.

*More specifically, the business purposes include: 

1. Performing services for you:

• To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
• To assist you in completing a transaction or order;
• To allow tracking of shipments;
• To prepare and process invoices;
• To respond to queries or requests and to provide services and support;
• To provide after sales customer relationship management;
• To create and manage our customer accounts;
• To notify you about changes to our services and products;
• To administer any promotion, contest, survey, or competition;
• To provide you information regarding our products and services,
• To offer our products and services to you in a personalized way, for example, we may provide suggestions based on your previous requests to enable you to identify suitable products and services more quickly.

2. Advertising customization:

• For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.

3. Auditing relating to transactions, internal research and development:

• To provide for internal business administration and operations, including troubleshooting, Site customization, enhancement or development, testing, research, administration and operation of our Sites and data analytics;
• To create products or services that may meet your needs;
• To measure performance of marketing initiatives, ads, and websites “powered by” another company on our behalf.

4. Security detection, protection and enforcement; functionality debugging, error repair:

• As part of our efforts to keep our Sites safe and secure;
• To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
• To ensure the physical security of our premises through the monitoring of surveillance images;
• To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.

5. Quality control:

• To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
• To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.