This California Privacy Notice (“Notice”) provides additional provisions that apply to residents of California. In the event of a conflict between this section and the Moonlight Graham Privacy Policy, this Notice shall take precedence for California residents. In this section only, any capitalized terms not defined in this Privacy Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).
Categories of Personal Information. We collect the following categories of personal information:
- Identifiers: Identifiers such as: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, or other similar identifiers.
- Customer Records: Any of the following types of information: telephone number, medical-related information.
- Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation Data
Categories of Sources From Which Personal Information is Collected.
The categories of sources from which your personal information is collected are:
- Directly From You: We collect personal information that you provide directly to us. Personal Information is required to use certain Platform features.
- Automatically: We automatically collect certain information from you when you access our Platform.
Purposes for Collecting Personal Information. Our purposes for collecting your personal information are described in Section 1(C) of the Moonlight Graham Privacy Policy.
Categories of Third Parties / Services Providers With Whom Personal Information is Shared. The categories of third parties and / or service providers with whom we share your personal information are described in Section 1(C) of the Moonlight Graham Privacy Policy.
Categories of Personal Information Sold
Moonlight Graham Sells certain de-identified information, which is information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer. Moonlight Graham uses the HIPAA safe harbor method to create the de-identified data sets that it sells.
In addition, Moonlight Graham has sold the following categories of personal information (that has not been de-identified) in the last 12 months:
- Identifiers
- Customer Records
Categories Of Personal Information Disclosed For A Business Purpose
In the last 12 months we disclosed the following categories of personal information for our Business Purposes, where “Business Purposes” has the definition set forth in the CCPA. See the section above titled “Categories of Personal Information” for more detail on the type of personal information in each category.
- Identifiers
- Customer Records
- Internet Activity
- Geolocation Data
- Employment Information
Your Rights to Access and Deletion. California residents have certain rights under the CCPA, such as the right to request certain information or request deletion of their personal information. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their personal information:
Right to Access. You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or Selling your personal information, (d) the categories of third parties with whom we shared your personal information, (e) the specific pieces of personal information we collected from you , and (f) a list of categories of personal information we disclosed for a Business Purpose in the last 12 months.
Right to Deletion. You have a right to request that we delete personal information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
How to Exercise Your Rights. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:
Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your request to exercise your rights under the CCPA: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.
When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive or repetitive.
Your Rights to Opt-Out of the Sale of Personal Information. California residents may direct us not to Sell their personal information at any time. You may submit your opt-out request here:
To opt-out online, please use this web-form.
Other ways you may opt-out include contacting us at the e-mail address set forth above.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA.
Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your own identity directly with us or directly confirm with us that you provided the authorized agent permission to submit the request.
Do Not Track. The Platform does not recognize “do not track” signals from your web browser.
Shine the Light. California law permits users that are residents of California to request the following information regarding our disclosure of their personal information to third parties for those third parties’ direct marketing purposes (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (iii) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please contact us through your Platform account.