CA Privacy Notice

Last Updated — Jan 11, 2024

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these CA Disclosures, personal information does not include:
• Publicly available information from government records.
• Deidentified, aggregated or anonymized data (not capable of being associated with or linked to you).
• Information relating to our job applicants, employees, contractors and other personnel of Overtext, which is not governed by these CA Disclosures.
• Certain information that we process solely on behalf of our business customers as a “service provider”.
• Information excluded from the CCPA’s scope, such as: (i) Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; (ii) Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Collection and Use of Personal Information

We collect various categories of personal information in connection with our services. Please review our Privacy Policy to learn more about the personal information we collect.

In the last 12 months we have collected the following categories of personal information:
• Internet/Network Information, such as log data and analytics data (including your usage and activity on our website). These are collected from your browser or device.
• Geolocation Data, such as your general geographic location based on the log data. These are collected from your browser or device.

The business purpose for the information collected as above is as follows:
(i) To provide you with and manage access to our products and services, audit the transactions in our platform and manage the relationship with our users;
(ii) To communicate with you, including via email, push notification and/or social media;
(iii) To operate, evaluate, secure and improve our business;
(iv) To enhance our products and services;
(v) To recognize you and remember your information when you return to our website and services;
(vii) For debugging existing intended functionality;
(viii) For testing, training, research, analysis and product development, including to develop and improve our products and services;
(ix) To detect and protect against security events;
(x) To defend, protect or enforce our rights or applicable terms of service;
(xi) To comply with legal process and our legal obligations; and
(xii) As otherwise provided in our agreements with you.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

(i) The Right to Know

You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information that we have disclosed about you to third parties, and the categories of recipients to whom this information was disclosed.

(ii) The Right to Request Deletion

You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

(iii) The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above.

However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

How to Exercise Your California Privacy Rights

To exercise your right to know and/or right to deletion, please submit a request by: (i) emailing with the subject line “California Rights Request”.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

California Shine the Light

We do not share or sell personal information with third parties.