TABLE OF CONTENTS
- Rights Afforded California Residents
- Rights Afforded to Virginia Residents
- Rights Afforded Nevada Residents
- Rights Afforded Canadian Residents
- Changes to this Policy
- How to Contact Us
1.Rights Afforded California Residents
This policy is included pursuant to the California Consumer Privacy Act, including as amended by the California Privacy Reform Act (collectively, the “CCPA”). This section applies to California residents (“consumers” as defined by CCPA) and explains our online and offline personal information practices when acting as a “business” under the CCPA.
A. Information We Collect and Disclose
In the past 12 months, the Company has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business purposes described below.
|Categories of PI Collected||Examples||Categories of Third Parties to Whom Disclosed|
|Identifiers||A real name, alias, postal address, unique personal identifier, company information, online identifier, Internet Protocol address, email address, telephone number.||• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants• Online analytics and marketing/advertising service providers• Professional advisors (accountants, lawyers)|
|Commercial information||Records of services purchased, obtained, or considered, including distribution and sales details.||• IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants• Marketing/advertising service providers• Financial institutions and payment processors• Professional advisors (accountants, lawyers)|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||• IT and cloud/hosting service providers• Online analytics and marketing/advertising service providers|
|Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, address, telephone number, employment information. Some personal information included in this category may overlap with other categories.||• IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers and IT consultants• Online analytics and marketing/advertising service providers • Professional advisors (accountants, lawyers)|
|Sensory data||Audio recordings, voicemail, or similar information.||• IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, and telephone communication providers|
B. How We Collect Your Information
The Company collects the categories of personal information listed above from the following sources:
Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, engaging in transactions with us, signing up to receive promotional or information communications from us, communicating with us about our podcast or services, or otherwise directly providing the information to us.
Indirect and technology-based collection: We also collect certain information from you indirectly when you visit, use, or navigate our website. The Company collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described above.
Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.).The type and scope of personal information obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by individuals, where applicable.
Third-party collection: From time-to-time, we may obtain marketing or lead lists from third party vendors. We use these, for example, to send you marketing communications.
C. Use of Personal Information
- Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most effective manner.
- Fulfilling transactions with you or your company, processing payments, and managing the business relationship and transaction process.
- Communicating with you and responding to your inquiries about our services and products, including to provide you with promotional and informational communications regarding our podcast or services, informing you about new services and products, updating you about changes to our services and products, and investigating any concerns you may have.
- Developing, updating, and improving our services and products, customer service, member experience, and marketing efforts, and otherwise improving our knowledge and insights regarding actual or potential providers, customers, and business partners.
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with our business and services.
- Enforcing our agreements and complying with our legal or regulatory obligations.
- Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
D. Applicable Retention Periods
The Company determines the retention period for each category of personal information based on the criteria set forth below in the section titled “Data Retention and Storage.”
E. Sensitive Personal Information
The Company does not collect “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, the Company treats any such information as “personal information” consistent with applicable provisions of the CCPA.
F. Sale or Sharing of Personal Information
In the past 12 months, the Company has not “sold” any categories of personal information, as defined by the CCPA.
In the past 12 months, the Company shared the following categories of personal information with (i) marketing/advertising service companies, and (ii) online analytics providers, for the purposes of cross-context behavioral advertising:
- Identifiers: Name, address, email address, device identifier, IP address, tags and identifiers for Google, Facebook/Meta, YouTube, Instagram, Convertkit, Unbounce, and OptinMoster.
- Internet and similar network activity: Site pages visited, duration of visit to Site, and referring website or advertisement.
The Company shared such personal information for the purposes of allowing such third parties to provide targeted advertising and cross-context behavioral advertising services to us and to others.
The Company does not have actual knowledge of any sales or sharing of personal information regarding minors under 16 years of age.
G. Rights Available Under the CCPA
The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.
- Right to Request Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past twelve (12) months. Specifically, you may request that we disclose:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- The business and commercial purposes for collecting your personal information;
- The categories of third parties to whom we disclose your personal information;
- The specific pieces of personal information we collected about you; and
- If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
- Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
- Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
- Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
- Right to Opt-Out. Consumers in California have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising.
H. How to Exercise Rights to Request Information, Data Portability, Deletion, and Correction
To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to legal[at]patientsafetyexperts.com with the subject line: “CCPA Request”. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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 may also request that you provide additional information if needed to verify your 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 or the consumer on whose behalf you are making the request.
Response timing and format. The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a 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 the request.
I. Exercising Your Right to Opt-Out of Sharing
To exercise your right to opt out of the sharing of your personal information, you or someone authorized to act on your behalf must submit a request using the following method:
- By emailing us at legal[at]patientsafetyexperts.com
The CCPA requires us to comply with a consumer request to opt out of sharing as soon as feasibly possible, but no later than fifteen (15) business days from the date the request is received. We may deny an opt-out request if we have a good faith, reasonable, and documented belief that the request is fraudulent. In the event we deny a request, we will inform the consumer and explain why we believe the request is fraudulent.
J. Our Commitment Not to Discriminate
Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by: (1) denying you services or products; (2) charging you different prices or rates for services or products, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of services or products; or (4) suggesting that you may receive a different price or rate for services or a different level or quality of services or products.
K. California’s Shine the Light Act
California Civil Code § 1798.83 (California’s Shine the Light Act) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.
2. Rights Afforded to Virginia Residents
This section is included pursuant to the Virginia Consumer Data Protection Act (the “VCDPA”). It applies to Virginia residents (“consumers” as defined by VCDPA) and explains our online and offline our personal information practices when acting as a “controller” under the VCDPA.
A. Categories of Personal Data We Process and Third Parties With Whom We Share Such Data
The categories of personal data that the Company processes about Virginia consumers is described in Sections 3 and 9(A) of this Policy. We share that personal data with the categories of third parties identified in Sections 5 and 9(A).
B. Purpose for Processing Personal Data
The purposes for which the Company processes personal data about Virginia consumers is described in Sections 4 and 9(C).
C. Consumer Rights Available Under the VCDPA
With respect to their personal data, Virginia consumers have the following rights, which are described in more detail in Section 9(F).
- Consumers have the right to confirm whether we are processing the consumers’ personal data and to access such data.
- Consumers have the right to correct inaccuracies in the personal data we are processing.
- Consumers have the right to delete personal data that they have provided to us or that we have obtained about them.
- Consumers have the right to obtain a copy of their personal data in a portable and readily usable format.
- Consumers have the right to opt out of the processing of their personal data for the purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
D. Exercising Consumer Rights
Consumers—or authorized representatives acting on their behalf—may exercise the rights described in bullets 1-4 above by submit a verifiable consumer request to legal[at]patientsafetyexperts.com with the subject line: “VCDPA Request”. Section 9(G) provides further information regarding the process for submitting such requests and the response timing and format.
Consumers may submit requests to opt out of targeted advertising via the methods described in Section 9(H). The Company does not “sell” consumers personal data or profile in furtherance of decisions that produce legal or similarly significant effects and, as such, the Company will not comply with such requests.
E. Appeal Process for Consumer Rights
As described in Section 9(G), when the Company denies or refuses to act on a consumer request, we will provide you with a written explanation of our reasons for doing so. You may appeal that decision by emailing us at legal[at]patientsafetyexperts.com with the subject line “VCDPA Appeal.” Your email shall describe the specific reasons you think our determination was incorrect. Within 60 days after receiving your email, we provide you with a written explanation of our any actions we have taken or not taken in response to your appeal. If we refuse to take action on your appeal, you may submit a complaint to the Virginia Attorney General by submitting this form or calling the Consumer Protection Hotline at (800) 552-9963.
3.Rights Afforded Nevada Residents
Pursuant to Nevada law, Nevada residents who have purchased services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in any activities that would qualify as a sale under Nevada law.
4. Rights Afforded Canadian Residents
If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to legal[at]patientsafetyexperts.com with the subject line, “Canada Resident Request,” or otherwise contact us using the information in the “How to Contact Us” section below. We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you.
5.Changes to this Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this Site after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
6.How to Contact Us
For questions or more information about our privacy practices, please contact us by e-mail at legal[at]patientsafetyexperts.com or by using the contact information provided below:
Creative Play Company LLC
5208 Magazine St Suite #253
New Orleans, LA 70115