CCPA Privacy Notice
CCPA Privacy Notice
Effective Date: February 10, 2021
This Privacy Notice for California Residents supplements the information contained in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“visitor”, “consumer”, or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights under the CCPA, please submit a verifiable consumer request to us:
By Mail:
After, Inc.
Attention: CTO
1 Selleck St., 5th Fl.
Norwalk, CT 06855 USA
By Email:
By Telephone:
Submitting a Verified Consumer Request
You have the right to submit verified consumer requests about:
- Specific pieces of personal information that After, Inc. has about you;
- Categories of personal information After, Inc. has collected about you;
- Categories of sources from which the personal information is collected;
- Categories of personal information that After, Inc. sold (if applicable) or disclosed for a business purpose;
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling personal information.
- The request to delete is to delete any of your personal information collected or maintained by After, Inc., subject to certain exceptions.
You may only make a verifiable consumer request to know information twice within a 12-month period. We cannot respond to your request or provide you with personal information, if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to provide enough information that allows us to reasonably verify that you are the person that we collected information about. We will not require you to incur any costs or fees in order to process or provide a verifiable request.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, JSON format.
Your Right to Request Deletion of Your Personal Information
You have the right to request that After, Inc. delete any of your personal information collected or maintained by After, Inc., subject to certain exceptions. You can do this through a verified consumer request as described below. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Response Timing and Format
Once we receive your verifiable consumer request, we will send you an acknowledgement letter within 10 business days which will describe our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. If we require more time (up to 45 calendar days), we will inform you of the reason and extension period in writing. Requests for deletion will require a separate confirmation that you want your information deleted.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Using an Authorized Agent to Submit Your Request
Only you, a person registered with the California Secretary of State, or a person you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code §§4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures in the section “Submitting a Verified Consumer Request.” If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.
Personal Information Sales Opt-Out and Opt-In Rights
While California residents have the right to opt out of the sale of their personal information under CCPA, we do not sell personal information to any third parties, and therefore, we have not included a “Do Not Sell My Personal Information” link on our Sites. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.
Additionally, we do not intend to market to any individual under the age of 18, and we expressly prohibit, anyone under the age of 16 from disclosing or submitting any personal information to us through our Sites or other means. Therefore, we do not sell any information of any individual under the age of 18.
Accessibility Statement
We are committed to making sure that our Site is accessible to everyone. To access this Privacy Policy in an alternative form, please call us at 800.374.4728.
Your Right to Non-Discrimination for the Exercise of a Privacy Right
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as stated below.
How To Contact Us
By Mail:
After, Inc.
Attention: CTO
1 Selleck St., 5th Fl.
Norwalk, CT 06855 US