Region Specific Privacy Notice

This Privacy Statement was updated on October 16, 2023.

This region specific privacy notice ("Notice") applies to all the products, services, websites and apps offered by Calibrum Inc. and its affiliates (collectively “Calibrum”), except where otherwise noted. Calibrum refers to these products, services, websites, and apps collectively as the “services” in this policy. Unless otherwise noted, our services are provided by Calibrum Inc. inside of the United States. This Notice is an extension to and forms part of the main Calibrum Privacy Notice.

This Notice describes the rights of individuals who are California residents under the California Consumer Privacy Act of 2018 ("CCPA"), and residents of other states or regions in the United States of America with similar applicable privacy laws who interact with Calibrum as a Service Provider. While we have set out the categories below as required by the CCPA and similar privacy laws, you can review our Privacy Notice for examples and other information that describes our data collection and use, as previously disclosed to you which have not changed under this Notice.

This Notice does not apply to personal information we collect from our employees or job applicants in their capacity as employees or job applicants. Employees and job applicants should refer to our Employee Privacy Notice or Candidate Privacy Notice, respectively. 

Except for residents of California, it also does not apply to personal information we collect from our employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services. 

Subject to certain restrictions, if you are a resident of California and states with similar privacy laws, you may have the right to request that we:

• confirm that we are processing your personal information or disclose what personal information we collect about you;
• delete any personal information that we collected from or maintain about you;
• correct inaccurate personal information we maintain about you;
• opt you out of any "sale" or "sharing" of personal information about you;
• opt you out of the processing of personal information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;  
• limit the use or disclosure of sensitive personal information if used or disclosed for reasons other than those permitted by the CCPA; and 
• not discriminate against you for exercising any of these rights.

Applicable laws may also give you the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us here. While our contact form is the best way to reach us, you may also email us at privacy@calibrum.com.

You have the right to request a copy of your personal information. Under the CCPA and similar privacy laws, you can also request that we disclose: the categories of personal information that we have collected about you; the categories of sources from which the personal information was collected; the business or commercial purpose(s) for which personal information was collected or “sold”; the categories of third parties with whom we share personal information; the categories of personal information that may have been “sold”, and the categories of third parties to whom the personal information was “sold” (if applicable); and the categories of personal information that we disclose for a business purpose, and the categories of third parties to whom the personal information was disclosed (if applicable).

However, as permitted under the CCPA, we may withhold some information where the risk to you or your personal information is too great to disclose the information, such as financial information or account passwords.

Subject to certain exceptions under applicable law, you have the right to request that we delete personal information that we have collected from or about you. However, we may retain personal information as authorized under applicable law, such as personal information required or necessary to provide our services, to protect against fraudulent activity, to identify and fix bugs, to exercise our or another person’s free speech or other rights, to comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

Subject to certain exceptions under applicable law, you have the right to request that we correct inaccurate personal information that we maintain about you.

You may exercise your access and deletion rights by submitting your request here. While our contact form is the best way to reach us, you may also email us at privacy@calibrum.com. For security purposes, we may request additional information from you to verify your identity when you request to exercise your rights related to your personal information.

If you have an online account with us, logging into your account will serve to verify your identity and request. If we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.

Once you submit a request (1) to access the categories of personal information we have about you or (2) to obtain a copy of specific pieces of personal information we have about you, we will ask that you verify your identity by logging into your account using your username and password. There, we will provide you with your information in a password-protected format.

To request that we delete personal information we have collected from you, you will need to authenticate with us by first logging into your account using your username and password on file with us and deleting your account. Once you let us know you have taken this action, we will initiate the deletion process. 

Most personal information can be corrected within your account. If you need instructions on how to do so, please contact us here. 

If you wish to exercise any of these rights and do not have an account with us (for example if you are an authorized agent submitting a request on behalf of another individual), please contact us here and we will request additional information to verify your identity where possible.

If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. 

The CCPA and similar privacy laws may prohibit us from discriminating against you for exercising the rights described in this section. Such discrimination may include charging different prices for our services, providing or suggesting that you will receive a different level or quality of services, or refusing to provide services to you if you exercise your rights. We will not discriminate against you for exercising your rights.

We collect the following categories of personal information:

• Identifiers (such as name, postal address, email address, phone number, or IP address)
• Legally protected classifications (such as gender )
• Commercial information (such as transaction data)
• Financial data (such as billing information)
• Internet or other network or device activity (such as browsing history or app usage)
• Location information (e.g. inferred from your IP address)
• Audio recordings (such as phone calls recorded for Customer Support or Sales purposes) 
• Professional or employment-related data (such as the name of your employer)
• Inferences drawn from other information we collect
• Other information that identifies or can be reasonably associated with you

Some of the personal information we collect may also be treated as “sensitive personal information” under the CCPA. We collect the following categories of “sensitive personal information”: 

• Your account log in details (username and password) 
• The contents of a consumer’s email where Calibrum provides email services 

All of the categories of personal information we collect about you come from the following categories of sources: 

• You, including through your use of our services 
• Automatically collected from you 
• Our affiliate companies 

If you interact with our site as a Respondent, all of your response data is controlled by the person or business who sent you the survey/form/application/questionnaire (the “Creator”) and we recommend you contact them about their practices under the CCPA and similar privacy laws, as Calibrum processes this response data on the Creator’s behalf and the Creator – not Calibrum – is responsible for responding to your request. 

We disclose all of the categories of personal information we collect about you (as detailed above) with the following categories of third parties:

• Our affiliate companies
• Aggregators (such as analytics services)
• Third parties (such as vendors that provide services to us and our integration partners)
• Your organization, through its purchase of an account with us, in the case of identifiers (such as name, postal address, email address, phone number, or IP address)
• Others with your consent

We collect, use, and disclose all of the categories of personal information and sensitive personal information (as detailed above) for the following commercial or business purposes:

• Providing our services (for example, account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our services)
• For our operational purposes, and the operational purposes of our vendors and integration partners
• Improving our existing services and developing new services (for example, by conducting research to develop new products or features)
• Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Short-term, transient use, such as customizing content that we or our vendors display on the services
• Other uses that advance our commercial or economic interests, such as third party advertising and communicating with you about relevant offers from third party partners
• Other uses that we notify you about

We do not use or disclose sensitive personal information for purposes other than for those purposes for which you cannot opt out under the CCPA. 

We retain your personal information for the periods described in our Help Center. 

The CCPA requires businesses that “sell” or "share" personal information, as the terms “sell” and "share" are defined under the CCPA, to provide California residents the right to opt-out from such sales or sharing. Sale and/or sharing are in such a way that may include allowing advertising vendors to receive certain information (such as cookie identifiers, IP addresses, and/or browsing behavior) to add to a profile (about your device, browser, or you). Such profiles may enable delivery of interest-based advertising by such advertising vendors within their platform or on other sites. When you visit our website, we may share the following categories of information for such interest-based advertising, which may be considered a “sale” or "sharing" as defined by the CCPA: (1) device information and identifiers, such as IP address and unique advertising identifiers and cookies; and (2) connection and usage information, such as browsing history or app usage. We engage in such practices to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. You may opt-out of such advertising cookies on a go-forward basis within our cookie banner or by contacting us through our Help Center.  

We do not “sell” or “share” sensitive personal information, as those terms are defined by the CCPA. 

Our services are not directed to consumers under 16 - and such minors are not authorized to use our services - so we do not knowingly “sell” or “share” the personal information of consumers under 16 years of age. 

For details on how to contact us, please see our Privacy Notice.