This Privacy Notice for California Residents (“CA Privacy Notice”) supplements the information contained in our Privacy Policy located at www.provalet.io/privacy-policy and applies to all visitors, users, and others who reside in the State of California (”consumers” or “you”) who use our Website, App or Service (each as defined and described in the Privacy Policy). Pure Coastal Technologies, Inc. d/b/a ProValet (“ProValet”/“we”/“us”/“our”) has adopted this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. With respect to users who are California residents, this notice is incorporated and made a part of our Privacy Policy, and the terms of this CA Privacy Notice shall control with respect to California residents in the event of any inconsistency between our Privacy Policy and this CA Privacy Notice. Where we use capitalized terms in this CA Privacy Notice that are not expressly defined, those terms have the meaning provided in the Privacy Policy.
I. Information We Collect
Our Website, App and Service (collectively and together with all related services and activities, our “Services”) collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect through our Website, App and Service, and have collected during the last twelve (12) months, the following categories of personal information:
- A. Identifiers
A real name, Internet Protocol address, email address, or other similar identifiers.
Collected? YES - B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Collected? YES - C. Protected classification characteristics under California or federal law.
A name, signature, Social Security number, physical characteristics or description, Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Some personal information included in this category may overlap with other categories.
Collected? NO - D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected? YES - E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected? NO - F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected? YES - G. Geolocation data.
Physical location or movements.
Collected? YES - H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Collected? YES - I. Professional or employment-related information.
Current or past job history or performance evaluations.
Collected? YES - J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected? NO - K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected? YES
For purposes of this CA Privacy Notice, personal information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information not capable of being associated with or be linked, directly or indirectly, to a particular consumer or household
- Information that is excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or personal information covered by certain privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994.
In general, we obtain the categories of personal information listed above from the following categories of sources:
- Directly from our users or their agents. For example, from forms our users complete on our websites or information they provide in connection with an account with us, through our communications with our users or through any other interaction we have with our users. This includes personal information relating to (1) purchasers of the goods and services offered by our users and (2) information related to the user’s workers and agents that such users input via the Services.
- Indirectly from our users and their agents. For example, from observing user actions on our website, or when someone authorizes a third party (including SNSs (as defined in the Privacy Policy)) to provide us the information on their behalf.
- Indirectly from our service providers. For example, third party service providers we use to help us provide aspects of the Services (such as payment processing) may receive personal information related to our users that we receive access to.
The ways that we collect the foregoing information are set forth in greater detail in our Privacy Policy.
Although this Section I and the corresponding portions of our Privacy Policy are designed, as described in our Privacy Policy and Terms of Service (located at www.provalet.io/privacy-policy), to disclose and describe our receipt and use of personal information of which we are aware, we do receive information from users of our Services, including User Content (as defined in the Terms of Service), in circumstances where we do not control or monitor what is contained in the information received. Accordingly, it is possible that we may receive unsolicited personal information falling in one of the categories described above under circumstances other than those described above. We endeavor to treat all personal information we receive consistent with the terms of our Privacy Policy, but cannot guarantee such treatment with respect to personal information, if any, that we may unknowingly receive as described in this paragraph.
II. Use of Personal Information
We may use the categories of personal information we collect as set forth above for the following purposes:
A. Identifiers.
- To provide our Services to our users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, to communicate with our users and perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services.
- Auditing related to a current interaction with consumers using the Services
- Advertising, marketing and selling the Services
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- To provide our Services to our users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, to communicate with our users and perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services.
- Auditing related to a current interaction with consumers using the Services
- Advertising, marketing and selling the Services
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
D. Commercial information
- To provide our Services to customers and other users, including facilitating purchases and payments via the Services. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
F. Internet or other similar network activity.
- To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity
- Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services.
- Auditing related to a current interaction with a consumer using the Services
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
H. Sensory data.
- To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
I. Professional or employment-related information.
- To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below.
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
K. Inferences drawn from other personal information.
- To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies.
- Undertaking activities to verify or maintain the qualify or safety of, and to upgrade and enhance, our products and services.
- Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction
In addition, we may use information in any of the categories described above:
- As described to you and consented to by you when collecting your personal information or as otherwise set forth in the CCPA.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or to otherwise comply with legal obligations applicable to us.
These uses of data, including personal information are described in greater detail in our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes from what is described in this CA Privacy Notice without providing you notice.
III. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose as set forth in this Notice. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, Company has disclosed personal information in the following categories for the business purposes identified above:
A. Identifiers.
- Our applicable service providers
- Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Our applicable service providers
- Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
D. Commercial information
- Our applicable service providers
- Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
F. Internet or other similar network activity.
- Our applicable service providers
G. Geolocation Data.
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
H. Sensory data.
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
I. Professional or employment-related information.
- Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us
IV. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
A. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we have collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
To make a request to have your personal information disclosed you can make a request for the information using the contact information set out in Section C below.
B. Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. 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.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 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.
C. Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us as follows:
(1) calling us at (239) 522-5440
(2) writing to us at Pure Coastal Technologies Inc, 365 5th Avenue South, Suite 201, Naples, Florida 34102, attention: Privacy Officer
(3) emailing us at: privacy@provalet.io. Only you, or a person registered with the California Secretary of State that 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 wish to register a person to operate on your behalf, you must inform us by contacting our customer services team and validating your identity so that the identity of the authorized person may be recorded.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it.
- 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
D. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within forty-five (45) days of receipt of your request. We will deliver our written response by mail or electronically, at your option. 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, specifically by electronic mail communication.
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.
E. Non-Discrimination
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.
F. California Shine the Light Law
California’s “Shine the Light” law (Civil Code Section § 1798.83) may permit users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, and to prevent future disclosures for direct marketing purposes of your Personal Information. To make such a request, please contact us using the contact information provided below.
V. Changes to this Notice
We reserve the right to amend this CA Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update this notice’s effective date. If as a business we intend to use your personal information for a purpose that was not previously disclosed in the privacy policy or in the notice at collection, we shall directly notify your of this new use and obtain explicit consent from the consumer to use it for this new purpose.
VI. Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described in the CA Privacy Notice and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: privacy@provalet.io or
ProValet Privacy Director
Pure Coastal Technologies Inc
365 5th Avenue South, Suite 201
Naples, Florida 34102