LightBox Privacy Notice for California Residents

Effective Date: March 2020

This Privacy Notice for California Residents (the “California Notice”) supplements the information contained in LightBox’s Privacy Policy and applies to the information LightBox and the LightBox group of companies (collectively, “LightBox,” “we” or “us”) collect about California residents (“consumers” or “you”), including our former, current and prospective clients and other individuals that access our website, use our services or communicate or engage with us.  This notice is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”), which requires that we provide California residents certain specific information about how handle their personal information, whether collected online or offline.    

This California Notice does not apply the personal information that we collect and process on behalf of and in order to perform our services to a particular business client; in such cases, we are acting as a “service provider” pursuant to the CCPA and will only collect and process personal information on behalf of and as directed by that client. It also does not apply to the personal information that we collect about employees, independent contractors and job applicants of LightBox.

Definition of personal information:

In this California Notice, “personal information” means information that identifies, relates to, describes, references is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident. It does not include publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under Section 1798.145(c) – (f) of the CCPA. 

Information We Collect and Disclose

The LightBox has collected and disclosed for a business purpose the following categories of personal information (as set forth in the CCPA) about California residents within the last 12 months:

 

Category	Examples	Collected	Disclosed for a Business Purpose
A. Identifiers.	Such as 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.	[YES]	[YES]
B. Customer records (personal information categories listed in Cal. Civ. Code § 1798.80(e).	Such as 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 included in this category may overlap with other categories.	[YES]	[YES]
C. Characteristics Protected classification under California or federal law.	Such as sex, age, religion, national origin, disability, or medical status.	[NO]	[NO]
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES]	[YES]
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.	[NO]	[NO]
F. Internet or other electronic network activity.	Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	[YES]	[YES]
G. Geolocation data.	Precise location information about a particular individual or device.	[YES]	[YES]
H. Electronic and sensory data.	Audio (e.g., call recordings), electronic, visual (e.g., photos and CCTV footage), thermal, olfactory, or similar information.	[YES]	[YES]
I. Professional or employment-related information.	Current or past job history or performance evaluations.	[YES]	[YES]
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education information and records related to a particular individual.	[NO]	[NO]
K. Inferences drawn from other personal information.	Inferences drawn from personal information to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes..	[Yes]	[YES]

 Categories of sources for personal information:

We may collect personal information:

• Directly: for example, from forms you complete or products and services you purchase from our web and social channels.
• Automatically: for example, from observing your actions on our Website.
• From third parties: for example, platform providers, telecom providers, data aggregators, social media sources, public records, and other third parties with whom we work to make available our products and services.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
•  As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sharing Personal Information

 LightBox may disclose your personal information as follows:

• Affiliates and subsidiaries: to our affiliates and subsidiaries, whose handling of your personal information is subject to this Policy.   
• Service providers: to third party vendors and service providers who perform functions on our behalf. Third party service providers will only process your personal information in accordance with our instructions and will implement adequate security measures to protect your personal information.
• Enterprise users: if you use, access or communicate with us about our products or services on behalf of your company (our client), we may share personal information about your access, and your communications or requests, with the relevant client.
• Compliance with legal obligation: in order to comply with the law, a legal obligation, judicial proceedings, a court order, or other legal process, such as a subpoena.
• To protect our rights: where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use and customer agreements, to respond to claims asserted against us or, or as evidence in litigation in which we are involved.
• Business and operations: such as relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
• Business transfers: as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.

 Aggregate, De-identified or Anonymous data. We may share aggregate, anonymous or de-identified data with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Sales of Personal Information

The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. We may disclose or make available certain categories of personal information to third parties, in order to receive certain services or benefits from them (such as when we allow third party advertisers and analytics providers to collect information on our Sites to improve and measure our ad campaigns. The personal information we disclose or make available to these third parties includes:

Name, contact information and other identifiers

•       Internet or other electronic network activity information
•       Profiles and inferences

Your Rights and Choices

The CCPA provides consumers (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 (“Right to Know”).  You have the right to submit a verifiable request that LightBox disclose certain information to regarding the personal information we have collected, used or disclosed about you over the past 12 months. If we are able to verify your request as required by the law, 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 categories of third parties to whom the residents’ personal information has been sold and the categories of personal information sold to each category of third party.
•       The specific pieces of personal information we collected about you.

Deletion Rights.  You have the right to submit a verifiable request that LightBox 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.

Do-Not-Sell Right.  You have the right to direct us to not sell your personal information at any time (the “right to opt-out” or “Do-Not-Sell Right”). We do not sell the personal information of consumers we have actual knowledge are under 16 years of age.  

Exercising Your Rights Under the CCPA

You may submit a request under the CCPA

info@lightboxre.com 

Or 

(888) 322-6277 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. When either you or your authorized agent submits a request to access or delete your personal information, we will attempt to verify your identity by matching the information provided to us as part of the request with the information we maintain about you in our records.  Authorized agents must also provide us with proof of written authorization to act on behalf of a particular consumer. You may also make a verifiable consumer request on behalf of your minor child. Consumers may only make a verifiable consumer request for access (i.e., a “request to know”) twice within a 12-month period.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that 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 write or email to us at: info@lightboxre.com

Changes to Our Privacy Notice

LightBox reserves the right to amend this California Notice at our discretion and at any time. When we make changes to this notice, we will post update the notice’s effective date and post the updated version on our Site.  

How to Contact Us

The full name of our company is LightBox Holdings, L.P., located at 6 Armstrong Road, Suite 4, Shelton, CT 06484. For all inquiries related to your personal information, or for any other questions or suggestions, please email us at info@lightboxre.com or call us at (888) 322-6277.