California Consumer Privacy Act Information

For California Residents
If you are a California resident, the information in this Privacy Policy Addendum (this "Privacy Policy Addendum") may apply to you, along with our general Privacy Policy and Terms of Service. Certain terms used in this Privacy Policy Addendum have the meanings given to them in the California Consumer Privacy Act ("CCPA") found at California Civil Code § 1798.100 et seq. The purpose of this Privacy Policy Addendum is to provide California consumers with a comprehensive description of our online and off-line practices regarding the collection, use, disclosure and sale of personal information, and the rights you may have as a resident of California regarding your personal information.
The CCPA defines "personal information" to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, de-identified or aggregate information. For purposes of this Privacy Policy Addendum we will refer to this information as "personal information."

Notification of Collection of Personal Information
Below (under the heading "Collection and Disclosure of Personal Information") is a list of the categories of personal information about California consumers which we may collect, the business or commercial purposes for which the personal information will be collected, and the categories of sources from which we collect personal information.

Notification of the Right to Opt Out of the Sale of Personal Information
California consumers may have the right to opt out of the sale of their personal information and the right to direct a business that sells personal information to stop selling the personal information and refrain from doing so in the future. We do not sell your personal information; however, you may opt out of the sale of your personal information by contacting us at: Support@IdentityPointCoaching.com

If you use an authorized agent to submit a request to opt out of the sale of personal information, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Collection and Disclosure of Personal Information
1.    Categories of Personal Information Collected. During the 12-month period prior to the effective date of this Privacy Policy Addendum we (directly or through our third-party vendors) may have collected and presently collect the following categories of personal information about California consumers:

• identifiers such as a real name, alias, postal address, unique personal identifier (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, Tax Identification Number, and other similar identifiers;

• signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information;

• commercial information, including records of products or services purchased, obtained, or considered;

• 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;

• audio, electronic, visual, and similar information;

• education information; and,

• 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.

2.      Business and Commercial Purposes for the Collection of Personal Information. For purposes of this Privacy Policy Addendum a "business purpose" means the use of personal information for our operational purposes and "commercial purposes" means to advance a person's commercial or economic interests such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods or services, or enabling or affecting, directly or indirectly, a commercial transaction. During the 12-month period prior to the effective date of this Privacy Policy Addendum we may have collected and presently collect personal information about California consumers for the following business and commercial purposes:

• performing Services (as defined below), 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 other services relating to ecommerce and direct marketing;

• 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 related to contractual or financial obligations or standards;

• 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 and analysis for marketing and technological and product development;

• undertaking activities to verify or maintain the quality or safety of a service or product;

• completing a transaction, providing a product or service, performing a contract, detecting and protecting against security incidents and malicious, deceptive, fraudulent or illegal activity or prosecuting those responsible, debugging to identify and repair errors that impair functionality, enabling solely internal uses, and complying with legal obligations, record retention and back-up practices, assisting in litigation or for other lawful purposes; and,

• advertising or marketing purposes of third parties, or enabling third parties to process, correct, enhance, or aggregate personal information or to assist us or third parties in any of the foregoing.

3.     Categories of Sources of Personal Information. During the 12-month period prior to the effective date of this Privacy Policy Addendum we may have collected and presently collect personal information about California consumers from the following categories of sources:
from you, for example, when you provide your name, postal address, telephone/mobile number, email address, credit card information and other data, and when you browse our website, register as a user of our website, place an order, purchase any service offered on or through our website, submit information to us or make other use of our website (our "Services");
your family and friends when they use our Services, such as by sending information about our Services directly to you;
our affiliates;
social media networks; and
advertising networks, list brokers and managers, list rentals and cooperatives.

Lists of Personal Information Disclosed

1. List of Personal Information Disclosed for Business or Commercial Purposes. During the 12-month period prior to the effective date of this Privacy Policy Addendum we may have disclosed for business or commercial purposes the following categories of personal information about California consumers to the following categories of third parties:
 

• Identifiers such as a real name, alias, postal address, unique personal identifier (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, and other similar identifiers;

• Information, including records of services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;

• 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; and,

• 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.

Categories of Third Parties to Whom Disclosed

1. Our affiliates

Vendors who provide services on our behalf, including, but not limited to, payment processors, internet service providers, network platforms, utility providers, search engines, web hosting providers, marketplace facilitators, collections processors, human resources service providers, staffing agencies, consumer reporting agencies, insurance carriers and brokers, consultants and professional advisers;

2.Our joint marketing partners

Third-party marketers (who may combine your personal information with their own records, and records available from other sources), for their own direct marketing purposes, and the direct marketing purposes of other third-party marketers.


Right to Know About Personal Information Collected, Disclosed or Sold
A California consumer may have the right to request that a business disclose what personal information it collects, uses, discloses and sells. You may submit a request to know (i) the specific pieces information we collect about you, (ii) the categories of personal information we collected about you, (iii) the categories of sources from which we collected the personal information, (iv) the business or commercial purposes for which we collected or sold the personal information, (v) the categories of third parties with whom we sold or disclosed personal information, and (vi) the categories of personal information about you that we sold or disclosed for a business purpose by contacting us at Support@IdentityPointCoaching.com

For security purposes we will verify your identity prior to providing any personal information about you or the personal information we collected or disclosed using a variety of methods including, but not limited to, by sending you an email to confirm your request and asking you for additional information such as your last purchase amount, customer number or other identifying information appropriate for verification.

See the Appendix below for a schedule of:

• the categories of personal information collected and sold or disclosed for a business purpose;

• the categories of sources from which we collected the personal information;

• the business or commercial purposes for which we collected or sold the personal information; and

• the categories of third parties with whom we sold or disclosed personal information in the preceding twelve months.

Right to Request Deletion of Personal Information
California consumers may have the right to request (not more than twice in any 12-month period) that their personal information collected or maintained by a business be deleted. You may submit a request for us to delete personal information we have collected or maintain about you by contacting us at Support@IdentityPointCoaching.com. We use “[at]” instead of “@” to prevent spam so we can actually see your message.

For security purposes we will confirm your request and verify your identity prior to deleting any personal information about you using a variety of methods including, but not limited to, by sending you an email to confirm your request and asking you for additional information such as your customer number or other identifying information appropriate for verification.

However, notwithstanding a verifiable request for deletion, we may retain certain personal information necessary for us to complete a transaction, provide a product or service, perform a contract, detect and protect against security incidents and malicious, deceptive, fraudulent or illegal activity or prosecute those responsible, debug to identify and repair errors that impair functionality, enable solely internal uses, and to comply with legal obligations, record retention and back-up practices, or for other lawful purposes.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
According to the CCPA and/or applicable law, businesses cannot discriminate against California consumers if they exercise any of the rights provided in the CCPA. This means that businesses cannot deny goods or services to that California consumer, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, provide a different level or quality of goods or services to the California consumer, or suggest that the California consumer will receive a different price or rate for goods or services or a different level or quality of goods or services. However, a business is permitted to charge a California consumer a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the individual's data.

We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise these rights or live in California.

Authorized Agents
You may use an authorized agent to submit a request to know, delete, or opt-out on your behalf, subject to verification of the authenticity of the request.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission, and (2) that you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of the sale of personal information, you will need to provide that authorized agent with written permission to do so and submit written proof to us that the agent has been authorized to act on your behalf.

Other California Consumer Privacy Rights
You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. See the "How To Contact Us" section for information regarding how to make such a request.

Changes to this Policy
We reserve the right to amend this policy at our discretion, at any time, and without notice. When we make changes to this policy, we will post the updated notice on the Site and update the notice's effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

How to Submit Requests or Contact Us
If you are a California resident and wish to make a CCPA request, please contact us at Support@IdentityPointCoaching.com. We will attempt to confirm receipt of your request within ten (10) business days. If your identity and request were verifiable, then we will attempt to respond within forty-five (45) days of the receipt of the request. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.