California Consumer Privacy Act (“CCPA”) Notice

Last updated February 7, 2020.

Introduction

This California Consumer Privacy Act Notice (“CCPA Notice”) supplements our Privacy Notice, as well as any other agreement you have with us, such as Apto’s Terms of Service. Capitalized terms have the same meaning as in the Privacy Policy or the CCPA (Cal. Civ. Code 1798.140). This CCPA Notice describes Apto's responsibilities related to the personal information of California consumers. This CCPA Notice describes the rights and choices that California consumers have with respect to their personal information, and ways to contact Apto to learn more about our privacy practices.

Data Collection

We collect limited amounts of business contact information and personal information to provide our services and operate our business. In the past twelve (12) months, we have collected the following categories of personal data:
  • Identifiers;
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
  • Commercial information; and
  • Electronic network activity.
For the purposes of this CCPA Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Please see the “Information We Collect and Receive from You” section in our Privacy Notice for more specific descriptions of the personal information we collect.Personal information under California law does not include:
  • Publicly available information;
  • De-identified or aggregated consumer information; or
  • Information excluded from the CCPA's scope such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Data Use and Sharing

Apto uses personal information for business purposes such as providing our services, resolving customer issues, maintaining the security of our Services, and conducting internal research to understand how customers interact with our Services. We share limited amounts of personal information with third party service providers, suppliers, vendors, and business partners to operate our business and provide our Services.In the last twelve (12) months we may have disclosed the following categories of personal information to third parties for our business purposes:
  • Identifiers;
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));
  • Commercial information; and
  • Electronic network activity.
For more information regarding Apto’s personal data use and sharing practices, please see the “How We Use Information” and “How We Share Information” sections of our Privacy Notice.Apto does not sell personal information to third parties.

Your Rights

The CCPA grants California consumers certain rights in connection with the personal information Apto holds about them. If you are a California consumer, you may have the right to:
  • Request access to the categories and specific pieces of personal information we have collected about you in the previous 12 months;
  • Request that we delete any personal information we have about you;
  • Request information about the collection and disclosure of your personal information from the previous 12 months; and
  • Not be discriminated against when you exercise your CCPA rights.

Exercising Your Rights

If you wish to exercise any of the above rights, please contact our Client using the email listed on our Client’s website or mobile application or contact us at the email or address listed in the “Contact Us” section of the Privacy Notice.To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your information. We will fulfill your request within 45 days of receiving your request. Please note that your request may be limited in certain cases (e.g., if complying with your request would impede us from meeting our legal obligations.)

Contact Information

If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact our Client using the email listed on our Client’s website or mobile application or contact us at the email or address listed in the “Contact Us” section of the Privacy Notice.