Effective Date: February 24, 2022
Last Updated on: February 24, 2022
This Privacy Policy for California Residents (“Policy”) supplements the information contained in Entrupy Inc.’s (“Entrupy”) Privacy Policy located at https://www.entrupy.com/privacy-policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” 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 Policy.
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, address, telephone number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. | YES |
C. Protected classification characteristics under California or federal law. | Age (40 years or older). | YES |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | 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. | NO |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | NO |
G. Geolocation data. | Physical location or movements. | YES |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
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. | NO |
K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
We obtain the categories of personal information listed above from the following categories of sources:
We may use or disclose the personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Entrupy Inc. has not disclosed personal information for a business purpose.
We do not sell personal information. In the preceding twelve (12) months, Entrupy Inc. has not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Personal Information Category | Category of Third-Party Recipients | |
Business Purpose Disclosures | Sales | |
A: Identifiers. | None | None |
B: California Customer Records personal information categories. | None | None |
C: Protected classification characteristics under California or federal law. | None | None |
D: Commercial information. | None | None |
E: Biometric information. | None | None |
F: Internet or other similar network activity. | None | None |
G: Geolocation data. | None | None |
H: Sensory data. | None | None |
I: Professional or employment-related information. | None | None |
J: Non-public education information. | None | None |
K: Inferences drawn from other personal information. | None | None |
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.
Right to Know and Data Portability
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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. Please note that:
You may also make a request to know or delete on behalf of your child.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
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.
You do not need to create an account with us to submit a request to know or delete. 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.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 our receipt of your request. 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 useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Personal Information Sales Opt-Out Rights
You have the right to request that we do not sell Personal Information that we have collected.
If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, email us at [email protected] and describe your request or call 1-888-368-7879
If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the website and update the notice’s effective date. Your continued use of the Entrupy Services following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which Entrupy collects and uses your information described here 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:
Phone: 1-888-368-7879
Website: www.entrupy.com
Email: [email protected]
Postal Address:
Entrupy, Inc.
Attn: Legal
750 Lexington Ave 8th Floor
New York, NY 10022
If you need to access this Policy in an alternative format due to having a disability, please contact [email protected] or by phone at 1-888-368-7879.
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