Supplemental States Privacy Policy
Updated September 25th, 2023
Specific states, including California, Colorado, Connecticut, Utah, and Virginia, require that we provide additional information regarding our privacy practices and your privacy rights. If you are a resident of these states, we provide you additional notices about our privacy practices and consumer rights relating to your information.
For California Residents:
California Privacy Notice Provisions: this section provides additional privacy rights for California residents (“User” or “You”) and applies to “Personal Information,” as defined by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020 (the “CCPA”), whether collected online or offline. This section describes our information practices and any rights you may have regarding your Personal Information pursuant to the CCPA.
Categories of Personal Information We Collect: for purposes of this section, “Personal Information” means 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. Please note that Personal Information does not include:
- Publicly available information, such as information lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience;
- Deidentified or aggregated information; and
- Information excluded from the CCPA's scope such as: 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; personal 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.
The following identifies the categories of personal information we collect about you, as enumerated by the CCPA. Depending on how you use the Services, we may collect the following categories of personal information through our Services:
- Identifiers: Name, contact information, unique personal identifier, online identifier, Internet Protocol address, email address, account information, or other similar identifiers.
- Commercial information: Transaction history, purchase record, financial details and payment information
- Internet or other electronic network activity: information on a consumer's interaction with an internet website or application.
- Geolocation data: device location information
- Customer Support: Inquiries for help and assistance of our Services
We may use your personal information for our business purposes including internal research for technological development to improve our Services. This is not considered to be “selling” of your personal data.
We do not sell any personal information to Third Parties for business or commercial purposes.
Your CCPA 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. Subject to certain exceptions, consumers have the right to make the following requests:
Rights to be informed (upon specific circumstances - you have the right to know):
- If we collect and use your personal information;
- The categories of personal information we collect;
- The purpose for which the collected personal information is used;
- The categories of third parties with whom we disclose Personal Information; and
- The specific pieces of Personal Information we have collected.
Right to Correct: Subject to certain conditions and exceptions, you have the right to request that we correct inaccuracies in your Personal Information.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure: We do not engage in uses or disclosures of “sensitive personal information” that would trigger the Right to Limit Use of Sensitive Personal Information under the CCPA.
Right to Delete your Personal Information: You have the right to ask for the deletion of your personal information. If you ask us to do so, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by other consumers of their rights to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities. Additionally, in accordance with applicable law, we are not obligated to provide or delete consumer information that is De-Identified in response to a consumer request or to Re-Identify individual data to verify a consumer request.
California “Shine the Light” Disclosure
California “Shine the Light” law (Civil Code Section 1798.83) permits users of our Services who are California residents to request, once per calendar year, certain information regarding our disclosure of Personal Information (if any) to third parties for their direct marketing purposes. To make such a request, please contact us at james@fevr.io. Please include in your request a current California address and your identification that you are a California resident.
The California Code of Regulations defines a “resident” as: 1.) every individual who is in the State of California for other than a temporary or transitory purpose and 2.) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents.” If this definition of “resident” is applicable to you, we must adhere to certain rights and obligations regarding your personal information.
California Financial Incentive Disclosure
California’s privacy law requires that we notify you if we provide you a program, benefit, or other offering, related to the collection, deletion, or sale of personal information, which it defines as a “financial incentive.” We may offer you certain financial incentives that may result in different prices, rates, or quality levels (for example: referral programs). Through these offerings, consumers provide us with some personal information (e.g., names, emails, phone numbers) when they opt-in to our programs. There is no obligation to opt-in and you may opt-out at any time. The details of each program are contained in the program offering. We offer these programs, among other things, to enhance our relationship with you so you can enjoy our Services at a lower price.
Retention of Your Information
We retain the personal information collected as described in this privacy policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Exercising Your CCPA Rights
If you are a California resident and would like to exercise your CCPA rights, please contact james@fevr.io.
Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that you directly verify your identity and the authority of your authorized agent.
Businesses operating as an authorized agent on behalf of a California resident must provide both of the following:
1.) Certificate of good standing with its state of organization; and 2.) A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the business to act on behalf of the California resident.
Individuals operating as an authorized agent on behalf of a California resident must provide either of the following: 1.) A notarized power of attorney signed and dated by the California resident naming the authorized agent as the California resident’s representative; or 2.) A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the individual to act on behalf of the California resident.
We reserve the right to reject (1) authorized agents who have not fulfilled the above requirements, or (2) automated CCPA requests where we have reason to believe the security of the requestor’s personal information may be at risk.
Verification: Before responding to your request, we must first verify your identity using the Personal Information you recently provided to us. You must provide us with your full name, email address you used to contact us, and your address (if applicable). We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request more information to verify your identity or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will provide explanation for the denial.
For Residents of Additional States:
If you live in Colorado (The Colorado Privacy Act - effective July 1, 2023), Connecticut (Connecticut Data Privacy Act - effective July 1, 2023), Utah (Utah Consumer Privacy Act - effective December 31, 2023), or Virginia (Virginia Consumer Data Protection Act - effective January 1, 2023), you may have the following rights:
1) The right to confirm whether we are processing your Personal Information, and to access your Personal Information.
2) The right to request we correct inaccuracies in your Personal Information.
3) The right to request we delete your Personal Information.
4) The right to request a copy of the Personal Information you provided to us.
5) The right to opt out of (i) processing of your Personal Information for advertising purposes, (ii) the sale of your Personal Information, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise rights (1) through (4), please contact us at james@fevr.io.
For 5 (i-iii), please note that we do not process your Personal Information for advertising purposes nor do we sell your Personal Information to Third Parties nor do we use your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects. Therefore, the consumer rights that apply to such decisions from these sections are not applicable to us.
Specific processing activities
De-identified or pseudonymous data: In addition to the collection of personal data as described in the Privacy Notice, we process de-identified data. With regard to our processing of de-identified data, we take reasonable measures to ensure the de-identified data cannot be associated with a natural person and commit to maintain and use such de-identified data without attempting to re-identify the data, and we require all of our service providers and partners in receipt of such de-identified data from us treat the data in the same manner.
Depending on your state of residence, you may have the right to appeal our decision to refuse to act based on your request. To do so, please contact us at james@fevr.io and attach or include information related to your original request.
Subject to applicable law, we may charge a fee to process or respond to any of your request if it is excessive, repetitive, or manifestly unfounded.