Privacy Policy

For California Consumers

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

• Identifiers. Identifiers such as a real name, postal address, unique personal identifiers (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;

• Additional Data Subject to Cal. Civ. Code § 1798.80. Signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information;

• Protected Classifications. Characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status;

• Commercial Information. Commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consumer histories or tendencies;

• Online Activity. Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;

• Geolocation Data. We use your IP address to determine your general location (such as city, state, or zip code);

• Sensory Information. Audio, electronic, visual, and similar information;

• Employment Information. Professional or employment-related information;

• Inferences. Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;

• Sensitive Personal Information

• Government ID. Government identification such as social security numbers, driver’s license, state identification card, or passport number;

• Account access information. Information such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;

• Precise geolocation data. Data derived from a device and that is used or intended to be used to locate you within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet;

• Sensitive demographic data. Racial or ethnic origin, religious or philosophical beliefs, or union membership;

• Biometric information. For the purpose of uniquely identifying an individual.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Legacy Logix Privacy Notice and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;

• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

• Debugging to identify and repair errors that impair existing intended functionality;

• Undertaking internal research for technological development and demonstration;

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. 

California Privacy Rights

Below are rights that are specific to California Residents. California residents also have additional rights as described in the California and Virginia Rights section below. 

Right to Opt-Out / “Do Not Sell or Share My Personal Information”. The CCPA requires us to describe the categories of personal information we sell or share to third parties and how to opt-out of future sales. It is important to know that the definition of “sale” and “share” is very broad and the common flow of information for advertising and analytics may be considered a sale or sharing. Legacy Logix does not provide information that you might typically think of as personal information to third parties in exchange for money; however, under the CCPA, personal information includes unique identifiers, including things like IP addresses, cookie IDs, pixel tags, and mobile ad IDs. The law defines a “sale” broadly to include simply making such personal information available to third parties in some cases. “Share” is defined as providing personal information to a third party to target advertising to a consumer based on information about their activity on multiple websites across the internet. In the last 12 months, when you access our online services, we may let advertising and analytics providers collect IP addresses, cookie IDs, advertising IDs, and other unique identifiers, which may be collected along with device and usage data, and information about your interactions with our online services and advertisements.

Learn more about how to opt-out in the “how to submit a request” section below.

Notice of Financial Incentive

Legacy Logix may offer rewards or prizes for participation in certain activities that may be considered a “financial incentive” under California law. These activities may involve the collection of personal information. The categories of personal information we collect is limited to what information you provide us, but may include: identifiers, protected class/demographic information, commercial information, online activities, geolocation information (general and precise), sensory information, employment information, and inferences. 

Activities we engage in that may be considered a financial incentive include surveys where we may provide compensation such as a gift card or SpotMe bonus in exchange for your time and responses, or a prize through your participation in promotions and sweepstakes. Participation in these programs may be subject to separate terms and conditions. Your participation in these programs is voluntary and you can terminate at any time as explained in any applicable terms.

When we offer gift cards in exchange for your participation in a survey or when we engage in promotions or sweepstakes, the amount provided is reasonably related to the value of the data you provide, which takes into account a number of factors, including, the anticipated benefit we receive such as product improvement, better understanding how you use our products, to enhance our understanding of consumer and market trends, increased consumer engagement, and the anticipated expenses we incur in relation to the collection, storage, and use of the information we receive. The value may vary across surveys, promotions, and sweepstakes.