California Consumer Privacy Act

California Consumer Privacy Act

Tradebe’S CALIFORNIA CONSUMER PRIVACY ACT STATEMENT

October 15, 2021

This Privacy Notice for California residents and addresses the requirements of the California Consumer Privacy Act of 2018 (“CCPA”).  Defined terms in the CCPA have the same meaning in this statement.

Information Collected

Tradebe collects information that may be used to identify, describe or link to people who visit our website and/or request information about our product or the products of third parties.  The CCPA identifies categories of personal information that may be collected. The table below indicates whether Tradebe has collected such personal information in the last 12 months, the source of that information, and whether it has been shared with a third party for a business purpose in the last 12 months:

Information Category

Examples

Collected in last 12 months?

Identifiers

Name, address, unique personal identifier, internet protocol (IP) address, [EK1] email address, phone number, account name, job title, industry, employer [Social Security number, driver’s license number, passport number]

YES, excluding bracketed information

Categories of personal information listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Name, address, telephone, education, employment, employment history [signature, social security number, physical characteristics or description, number, passport number, driver’s license, or state identification number, insurance policy number, bank account] number, financial information, medical information, health insurance information]

YES, excluding bracketed information

Protected class characteristics under California or federal law

Age, race, color, ethnicity, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identify, gender expression), sexual orientation, veteran or military status, genetic information (including familial information)

NO

Commercial Information

Personal property records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

NO

Biometric Information

Genetic, physiological, behavioral, or biological characteristics, eye scans, face prints, finger prints, sleep, health or exercise data

NO

Internet or other electronic network activity information

Browsing history, search history, information regarding the consumers interaction with a website, application or advertisement

YES

Geolocation data

Physical location or movements

NO

Sensory data

Audio, electronic, visual, thermal, olfactory information

NO

Professional or employment-related information

Current or past job history or performance evaluations

NO

Nonpublic education information as defined in the Family Education Rights and Privacy Act

Education records related to a student maintained by an educational institution or party acting on its behalf, such as student grades, transcripts, class lists, schedule, identification codes, financial information or disciplinary records.

NO

Inferences drawn from any of the information identified above

Information is used to create a profile of consumer’s preferences, [characteristics, psychological trends behavior, attitudes, intelligence, abilities, and aptitudes]

YES, excluding bracketed information

 

Tradebe’s Use of your Personal Information

 

Personal information collected from you may be used for one or more of the following business purposes:

  • To address your inquiries associated with the information you provided to us;
  • To provide you with products, services, and information you request from Tradebe or Tradebe partners;
  • To provide you with emails, event notifications, invitations, newsletters, announcements and other communications regarding our products, services, and matters that may be of interest to you;
  • To meet our obligations and enforce our rights under contracts we enter with you for our products and services;
  • To improve our website content and how it is presented to you;
  • To analyze for product development;
  • To comply with requests for information required by law.

 

Tradebe does not sell the personal information we collect from you. 

 

California Residents’ Rights under the CCPA

 

You have specific rights regarding how your personal data is collected and used.

  • You have the right to request that Tradebe disclose our collection and use of your personal information during the past 12 months, specifically:
    • Categories of personal information collected;
    • Sourced of personal information collected;
    • Our business purpose for collecting (or selling) that personal information;
    • Categories of third parties with whom we share your personal information;
    • Categories of personal information sold or disclosed to third parties.
  • You have the right to request a copy of the personal information collected prior to your request in the past 12 months;
  • You have the right to request deletion of that information (with exceptions noted by law);
  • You have the right to request that your personal information not be sold to third parties, if applicable; and
  • You have the right not to be discriminated against because you exercised these rights.

 

We will respond to your verifiable request to disclose and or delete your personal information within 45 days, providing you with an electronic copy of your information; however, if we up to an additional 90 days as permitted under the CCPA to respond, we will inform you within 45 days of your request.  

 

In the event you request deletion, Tradebe will be unable to do so, as permitted by the CCPA, in event the personal information is necessary to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between Tradebe and you;
  • Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
  • 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 our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation;
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.

 

How to Contact Tradebe to Exercise Your Rights

You can submit your request for disclosure, copies or deletions of your personal information to Tradebe by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information):

us.communications@tradebe.com

(800) 388-7242

The CCPA restricts you to two verifiable requests within a 12-month period.  Only you or a person registered with the California Secret of State that you authorize to act on your behalf may make a verifiable request regarding your personal information. Tradebe cannot respond to a request if we are unable to verify your identity or authority to make the request on behalf of another.  Please provide information sufficient to confirm your identify or your authority to make the request on behalf of another, and describe your request with sufficient detail that allows us to understand and respond to your request. We will endeavor to respond to your request within 45 days of receipt.  If more time is required (up to 90 days), we will inform you of the reason and extension of time required.  There is no fee charged for processing your request.

Reservation of Rights

Tradebe reserves it rights with regard to any verifiable request, its evaluation of what is necessary to comply with the CCPA, and to amend this notice at any time within Tradebe’s discretion.