REFINU INC.

PRIVACY POLICY

SUPPLEMENT FOR CALIFORNIA RESIDENTS

 

Last Updated

8/15/21

 

Overview

This Privacy Policy Supplement for California Residents supplements the general Privacy Policy of Refinu Inc. (“Refinu”, “we”, and “us”) for California residents who visit the www.refinu.com website (the “Site”). Amendments to this Supplement will be posted to the Site and will be effective when posted. Your continued use of the Site following the posting of any amendment to this Supplement shall constitute your acceptance of such amendment.

 

Your California Privacy Rights

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

 

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provide it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights, please submit a verifiable consumer request to us by emailing us at info@refinu.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12 month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person we collected personal information on.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

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. Making a verifiable request does not require you to create an account with us.

 

Response Timing and Format

We endeavor to respond to verifiable consumer requests within 45 days of receipt. 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 to you by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, we will also provide reasons we cannot comply with your request. 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. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine a fee is warranted, we will provide you with an estimate before completing your request.

 

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us not to sell your personal information (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years or age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you may submit a request by visiting the following link: [INSERT hyperlinked URL with the title “Do Not Sell My Personal Information”)]. You may opt back in to personal information sales at any time by following this link [INSERT hyperlinked URL]

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you with a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services. 

California Civil Code Section §1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@refinu.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.

 

Information We Collect

Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to, directly or indirectly, with a particular consumer or device (“personal information”). In particular the website has collected the following categories of personal information from its consumers within in the last 12 months:

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Collected [YES/NO]

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information in this category may overlap with other categories.

Collected [YES/NO]

C. Protected classification under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected [YES/NO]

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected [YES/NO]

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.

Collected [YES/NO]

F. Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Collected [YES/NO]

G. Geolocation data

Physical location or movements.

Collected [YES/NO]

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or other similar information.

Collected [YES/NO]

I. Professional or employment-related information

Current or past job history or performance evaluations.

Collected [YES/NO]

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 24 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.

Collected [YES/NO]

K. Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected [YES/NO]

The term “personal information” does not include:

  • Publicly available information from government records; or

  • Deidentified or aggregate consumer information.

 

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

[Category A: Identifiers]

[Category B. Personal information categories]

 

Sale of Personal Information

In the preceding 12 months, we have not sold personal information for a business purpose.

 

Contact Us

If you have any questions or comments about this Supplement, please contact our Privacy Officer by email at privacy@refinu.com.

 

Refinu Inc.