Supplemental California Privacy Notice

This Privacy Notice for California Residents supplements our main privacy policy and applies to those who live in California and whose personal information Ubimo processes as a “business.” It does not apply to personal information we collect in the following circumstances:

From employees or job applicants in their capacity as employees or job applicants;
Personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services; and
Information that we process as a service provider on behalf of other businesses.

A. Categories of Personal Information that We Collect and Share

The California Consumer Privacy Act (“CCPA”) requires us to give California residents certain information about the categories of personal information we collect and how we use it, the categories of sources of the information, and the categories of third parties with whom we share the information during the past twelve months. While we have set out the categories below as required by the CCPA, you can review our main privacy policy for more detailed information that describes our collection, sharing, and use. Depending on how you interact with us, we may collect and share the categories summarized below.

Categories of Personal Information We Collect	Categories of Sources of Personal Information	Categories of Third Parties that We Share Personal Information With
Identifiers (such as name, address, email, phone number, online identifier, device ID) excluding Contact Information and other data collected on our Website	You Automatically collected from you or your device Affiliates or subsidiaries Sevice providers Data partners	Advertising and Measurement Partners
Commercial Information (such as transaction data) excluding Contact Information and other data collected on our Website	Affiliates or subsidiaries	Advertising and Measurement Partners
Internet or Other Network or Device Activity (such as browsing history, search history, interaction with advertisements) excluding Contact Information and other data collected on our Website	Automatically collected from you or your device Affiliates or subsidiaries Service providers	Advertising and Measurement Partners
Demographic Information (such as state of residence, household income range, education level, occupation, and certain legally protected characteristics such as gender, age, ethnicity, and military service) excluding Contact Information and other data collected on our Website	Affiliates or subsidiaries Service providers Data partners	Advertising and Measurement Partners
Location Information (e.g., inferred from your IP address or web beacon) excluding Contact Information and other data collected on our Website	Automatically collected from you or your device Affiliates or subsidiaries Service providers Data partners	Advertising and Measurement Partners
Contact Information and other data collected from our Website which may constitute Identifiers, Commercial Information, Internet or Other Network or Device Activity, Demographic Information, or Location Information	Automatically collected from you or your device Affiliates or subsidiaries Service providers	None

Please note that we may also disclose all personal information to (a) our Service Providers; (b) our affiliates and subsidiaries; (c) comply with federal, state, or local laws; (d) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (e) cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (f) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (g) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

B. Categories of Business/Commercial Purposes for Our Use of Your Information

All of the categories of personal information we collect about you (as detailed above) are used for the following purposes:

Delivering and measuring relevant ads, offers or promotions to you
For our operational purposes
Improving our existing Platform and developing new products and services
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity
Bug detection, error reporting, and activities to maintain the quality or safety of our Platform
Auditing consumer interactions (for example, measuring ad impressions)
Short-term, transient use, such as customizing content that we or our service providers display to you
Advertising, marketing, measurement and analytics, on our Platform
Other uses that advance our commercial or economic interests, such as third-party advertising and communications about relevant promotions or offers from third parties
Advertising, marketing, measurement and analytics, on our Platform
Other uses that advance our commercial or economic interests, such as third-party advertising and communications about relevant promotions or offers from third parties
Additional uses disclosed in our main privacy policy
Other uses that we notify you about

We also use your Device Data, PLI, and Combined Data to provide services for, and products to, our Advertising and Measurements Partners (as described in our Privacy Policy).

C. Opt Out of Sale of Personal Information

The CCPA defines “sale” and “personal information” very broadly. Certain uses of your data described above may constitute a sale under the CCPA, as we currently understand it. If you would like to opt out of our use of your information for purposes that are considered a “sale” under California law, you may do so here. If you want us to delete tracking cookies that enable targeted advertising, which allow us to provide promotions and offers relevant to you, you may do so here. If you clear your cookies after you asked us to delete tracking cookies, we will not be able to know that you made this request so you will need to opt out again. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization. We do not sell the Contact Information you provide us through our website.

D. California Residents’ Privacy Rights

Subject to certain restrictions, California residents have the right under the CCPA to request that we:

Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.
Honor your opt-out of the “sale” of your information.

Note that in response to requests to access specific pieces of information we have collected that are only associated with a specific device identifier, we cannot provide such specific pieces of information because we are unable to adequately verify that the person who has submitted the request is the actual owner of the device associated with a given data set. For example, a person in possession of another person’s phone could potentially have access to that phone’s device ID, and submit an unauthorized access request by providing that ID.  We seek to avoid a situation where such a person might obtain potentially sensitive data pertaining to the phone’s owner. Moreover, because we do not associate other personal information such as name, address or email address with this data, we do not have other, more conventional ways to adequately verify the identity of an actual device owner. 

If you do submit an access request, we can let you know whether we generally have data associated with the device identifier you have submitted to us. If you prefer that we delete the information we have associated with your device, you can submit a deletion request as described below.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion, or sale opt-out rights. We will not discriminate against you for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, for financial auditing purposes, and for compliance with applicable law.

If you would like to exercise any of these CCPA rights, you may either visit our privacy portal to complete the request form or send an email to info@ubimo.com. If you submit your request by email, please include “CCPA Request” in the email subject line and include, in the body of the email, you name (First and Last), email address, state and zip code of residence, and a description of the CCPA rights you wish to exercise.

Additionally, you may submit a request to delete your information or a request for the information that we have collected about you by calling the toll-free number 1-888-914-9661. When prompted for your PIN number, enter 434203. After entering the PIN, you will be taken to the Ubimo Call Center. Please listen carefully and follow the instructions. When prompted to provide your name and email address, please speak in a loud, clear voice and spell out your name and email address. When you finished providing the information, you must press “#” to complete submission of your request. If you do not press “#” to end your recording, your request will not be submitted. Note that when using the toll-free number, you will need to make a separate call for each request you wish to exercise (i.e. one call to submit a request to know and a separate call to submit a request to delete). If we are not able to understand the information you have provided, we may call you on the number you used to call the toll-free number, if it is available, in order to confirm your information.

After submitting your request(s), we are required to verify your request(s) to ensure it is not fraudulent. To verify your request, we will contact you via the email address you provided with your request. We will require you to provide a screenshot from your device showing the devices advertising identifier, sometimes referred to as Identifier for Advertising (IDAF) on Apple devices or Google Advertising Identifier (AAID) on Android devices. Further, we may require you to confirm ownership of the email address associated with your request or provide additional information necessary to verify the validity of your request. For example, we may ask for you to provide additional information to determine if it matches information we have. Please be sure to check your SPAM/junk folder in case the email is filtered out by your mail system. If you do not receive an email from us regarding your request(s) within 48 hours, your request or contact information may not have been submitted properly, and you will need to submit a new request.

You may also designate an authorized agent to make a request on your behalf. To do so, you must provide us with a copy of written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

This policy was last updated on 9/14/2020.

Supplemental California Privacy Notice