California Consumer Privacy Act

This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like us, that receive information from more than fifty thousand California consumers, to provide certain information to them. We fully describe our practices to all our users and guests in our Privacy Policy, but use this separate notice to ensure that we meet the CCPA’s requirements. This notice contains the following four parts:

  • We Do Not Sell Your Personal Information
  • Your CCPA Rights
  • The CCPA Categories of Personal Information We Collect and the Sources
  • The CCPA Categories of Personal Information We Share for a “Business Purpose”

1. We Do Not Sell Your Personal Information

The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information.

2. Your Rights Under the CCPA

The CCPA provides Californians with the following rights:

2.1 Requests for Information

Like all of our users, you (or your authorized agent) can request a copy of your personal information. Under the CCPA, you can also request that we disclose how we have collected, used, and shared your personal information over the past 12 months, including the categories of personal information we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. Companies that sell personal information (we do not) must make additional disclosures.

If you are not a SpringPath user, you can submit your request via email to [email protected]

2.2 Your Right to Opt Out of Sales

We do not sell personal information, so we don’t have an opt out.

2.3 Your Right to Notification

Under the CCPA, a company like SpringPath cannot collect new categories of personal information or use them for materially different purposes without first notifying you.

2.4 Nondiscrimination for exercising your CCPA Rights

The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.

2.5 Your Right to Delete Personal Information

Like all of our users, you can request that we delete your personal information by closing your SpringPath account. You also can request that we delete specific information. We honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.

3. The CCPA Categories of Personal Information We Collect and the Sources

Our Privacy Policy describes the information we collect and its sources. This notice organizes that information around the personal information categories set forth in the CCPA.

CCPA Personal Information Category Sources of this Information
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers) Information you provide directly or through your interactions with our Services (as defined in our Privacy Policy) or partners (as described in Sections 1.2 and 2.4 of our Privacy Policy)
Vendors that provide information to help us serve users relevant ads and understand the ads’ effectiveness
Information from other SpringPath users or customers
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”) Information you provide to us directly and inferences we make based on that information
Information from our customers
Commercial information (e.g., information regarding products or services purchased, obtained, or considered) Information you provide to us directly, such as to buy a Premium service
Your interactions with our Services
Information from our partners and customers
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services) Your interactions with our Services
Your visits to third party sites that offer our autofill, follow or “Apply with SpringPath” functionality, as needed for fraud prevention and security purposes.
If you are a user, your interactions with the services of partners and customers that use the SpringPath platform. 
Geolocation Data Information you provide to us directly or through your interactions with our Services, as explained in Section 1.5 of the Privacy Policy
Professional or Employment-Related Information Information you provide to us directly
Information from our customers, partners, or from other users (e.g., if a connection endorses you)
Inferences Information you provide to us directly or through your interactions with our Services
Information from our customers and partners
Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number) Information you provide directly or through your interactions with our Services
Information from our customers or partners
Audio, electronic, visual or similar information Information you provide directly or through your interactions with our Services, customers or partners

We use this personal information for the purposes outlined in Section 2 of our Privacy Policy.

4. The CCPA Categories of Personal Information We Share for a “Business Purpose”

While we do not sell your personal information, we may share it to support our own operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, we may share personal information at your direction, such as when you choose to communicate with other users through our Services.

4.1 Auditing Interactions

We may share the types of personal information listed in Section 3 with partners, service providers and related companies, in order to audit interactions and transactions, such as to count or verify the positioning and quality of ad impressions.

4.2 Security Purposes

In order to secure our Services, including to detect, prevent and investigate security incidents or violations of our Professional Community Policies or applicable laws, we may share the types of personal information listed in Section 3 with our partners, service providers, law enforcement and related companies.

4.3 Service Improvements

In order to improve our Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of personal information listed in Section 3 with our partners, service providers and related companies

4.4 Service Providers and Other Notified Purposes

We may share the types of personal information listed in Section 3 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).