ACUANT
CALIFORNIA AND VIRGINIA PRIVACY NOTICE

Effective Date: December 30, 2022

Scope Of Notice

This California and Virginia Privacy Notice (the "US Notice") supplements the information contained in our general Privacy Notice and applies solely to individual residents of the States of California and Virginia (collectively, "consumers" or "you").

This US Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the States of California and Virginia, either online or offline, within the scope of the California Consumer Privacy Act of 2018 and its corresponding regulations, as amended by the California Privacy Rights Act, and the Virginia Consumer Data Protection Act, both as amended from time to time (collectively, the "US Privacy Laws").

Unless otherwise expressly stated, all terms in this US Notice have the same meaning as defined in our general Privacy Notice or as otherwise defined in the relevant US Privacy Law.

When we use the term "personal information" in this US Notice, 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, or natural person. For the purposes of this US Notice, personal information does not include:

  • Publicly available information from government records;
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer; and
  • Any other data that is exempt from qualifying as personal information under the relevant US Privacy Law.

Collection And Use Of Personal Information

We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect and how we use this information, please refer to our general Privacy Notice. To learn more about the types of personal information our products and services collect and how we use this information, including duration of retention, please refer to our Product Privacy Notice.

We have collected/processed the following categories of personal information, as follows:

Personal Data Categories Sources of Personal Data Business or Commercial Purpose for Collection Have we Sold the Personal Data to Third Parties With Whom We Share Personal Data

Identifiers, such as your name, date of birth, phone/mobile number, and email address, identification documentation (e.g., drivers licenses, passports, and other government issued ID documents) and its corresponding data

Identifiers include California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your such as real name, address, telephone number, email address, IP address, date of birth, login name or handle, and other similar identifiers

You or Acuant partners/customers to whom you provide it to.

To enable use of our Sites, Services, products, to communicate with you, to understand how our users interact with our Sites, to improve our offerings, to market our products or services, to secure our Services, to fulfil our legal compliance obligations, in connection with a business merger or transaction, and otherwise for internal business purposes and to comply with applicable legal requirements.

Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

We share this information with our service providers, and with business partners and affiliates, in order to enable our Services and products to function.

Financial information, such as credit or debit card information, and account numbers

You or Acuant partners/customers to whom you provide it to.

To transact with you if you use our products or services, to enable transactions you’ve requested, and otherwise for our own internal business purposes. Additionally, we may also use this information to enable our services and products to function, if not provided in a B2B/employment capacity.

* Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

*Excluding employment purposes, for which no sale of personal data is performed

We share this information with our service providers and business partners and affiliates, in order to enable our Services and products to function

Commercial information and preferences, such as product purchase history, and contact information (name, job, title, work email, phone, and address) (solely in relation to our B2B transactions with our customers).

You

To transact with you, in your capacity as a B2B employee, if you use our Sites, products, or services, to enable transactions you’ve requested as a B2B employee, to market our products or services, and for our own internal business purposes such as record-keeping

No

We share this information with our service providers, third party advertising and analytics partners, and business partners and affiliates, in order to enable our Services and products to function

Internet or other electronic network activity information on this Site, such as system version, browser type, internet service provider, browsing history, websites visited prior to our Sites, cookie IDs, device type, details about how you use our Site, the referring web page and pages visited, and other similar activity information

Your device

To enable use of our Sites, services, and products, to communicate with you, to understand how you interact with our Sites, to secure our Services, to market our products or Services, and to improve our offerings

No

We share this information with our service providers, third party advertising and analytics partners, and business partners and affiliates, in order to enable our Services and products to function

Internet/Network Information, such as device information, IP address, device address, logs and analytics data;

You or Acuant partners/customers to whom you provide it to.

To enable use of our services and products.

Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

Image: Photo on a passport, driving license, or other identification document, (including the personal information contained therein), self-taken photos

You or Acuant partners/customers to whom you provide it to.

To enable use of our services and products.

Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

We share this information with our service providers, third party advertising and analytics partners, and business partners and affiliates

Sensitive Personal Information: your geolocation, driver’s license and passport numbers, social security numbers, citizenship/immigration status contained in passports;

Biometric Information, meaning facial algorithms match scores for the purpose of authenticating ID documents

Information Pertaining to Minors and Children, our customers may provide us with passports and medical insurance cards pertaining to individuals who fall under this age group. We do not target this group for collection ourselves and cannot control the data that our customers provide to us. We only knowingly process minor information under our Identity Services as a service provider/processor and do not sell personal information thereunder.

You or Acuant partners/customers to whom you provide it to.

To enable use of our services and products. For employees, we would collect this for standard and/or legally mandated hiring and HR purposes.

* Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

*Excluding biometric information and for employment purposes, for which no sale of personal data is performed.

We share this information with our service providers and business partners and affiliates, in order to enable our Services and products to function

Professional or employment-related information, such as job title, employment history, background checks, and organizational affiliation

You, or any third party to whom you have granted permission to provide us with the relevant personal information

To provide services or products you’ve requested, to comply with applicable legal obligations, and for internal business purposes. For employees, we would collect this for standard and/or legally mandated hiring and HR purposes

No

We share this information with our service providers and business partners and affiliates, in order to enable our Services and products to function

Inferences: such as information generated from your interactions or transactions with our clients (which they provide to us) to create risk scores for fraud prevention and regulatory compliance purposes.

You or Acuant partners/customers to whom you provide it to.

To enable use of our services and products.

Yes, to our Compliance Service customers, to whom you provided the information to, and our technology providers, in order to enable our Services and products to function.

We share this information with our service providers and business partners and affiliates, in order to enable our Services and products to function



The purpose(s) for collecting your personal information is as follows:

Cookies And Other Technologies

Acuant’s websites and advertisements may use "cookies" and other technologies such as web beacons for a variety of commercial reasons, including the ability to measure the effectiveness of our advertisements, based on web searches, for example. For more information on our advertising practices that utilize cookies, please see our Cookie Notice.

Your US Privacy Rights

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

The Right to Know

You have the right to request information on the personal information we collected about you in the last 12 months, including the categories of personal information, the categories of sources from which your personal information was collected from, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third parties to whom we disclosed your personal information to, and the specific pieces of personal information we have collected about you.

The Right to Delete

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions, as set out under your relevant US Privacy Law.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future, as set out under your relevant US Privacy Law.

Please note that Acuant does not sell any personal information that it collects via its Identity Services products as it only processes information thereunder as a B2B service provider/processor.

However, Acuant does sell personal information when it is processing data under its Compliance Services, as further detailed in our Product Privacy Notice. We use the categories of personal information detailed above, including the special personal information categories, to provide our Compliance Services to our customers for them to verify their customers’ information for the purposes of fraud detection/prevention and compliance with laws that may apply to them (e.g., Anti-Money Laundering checks). To make a request to opt-out of the sale of your personal information please use our Opt-Out Webform.

The Right to Correct Inaccurate Information

You have the right to request that we correct inaccurate personal Information that we have on you, taking into account the nature of the personal Information and the purposes of the processing of the personal Information, as specified under your relevant Data Protection Law.

The Right to Limit the Use of Sensitive Personal Information

You have the right, at any time, to have us limit the use of your sensitive personal information to usage that is strictly necessary to perform the services or use expected by an average consumer who requests such goods or services. Please note that we will not use or disclose your sensitive personal information for purposes other than those specified in section 7027 of the California Consumer Privacy Act regulations, subsection (m).

The Right to Non-Discrimination

You have the right not to receive discriminatory or retaliatory treatment for exercising these rights.

"Shine the Light"

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s "Shine the Light" law (Civ. Code §1798.83).

How To Exercise Your US Consumer Rights

To Exercise Your Consumer Rights

To exercise any of your consumer rights, please submit a request via either of the following methods:

Before processing your request, we will need to verify your identity and confirm you are in fact a resident of the State of California or Virginia.

Verification: In order to exercise your rights, we will need to obtain information to locate you in our records and verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth in this section.

For Right to Know, Right to Correct, and Right to Delete, we will request an ID Document, as well as information on your First Name, Last Name, Email Address, Phone, Postal Address, and Date of Birth to verify your identity and ask that you declare, under penalty of perjury, that you are who you say you are.

For Right to Opt-Out, we will only request that you provide us with First Name, Last Name, Email Address, Phone, Postal Address, and Date of Birth (but we will not verify your identity and therefore will not need you to provide an ID document).

Opt-Out Preference Signal: If you have enabled your opt-out preference via a compatible web browser (i.e., DuckDuckGo and Brave)., our opt-out preference signal will be applied to your browser when you visit our Site.

To Exercise Your Right to Opt Out of Personal Information Sales

Please use our Opt-Out Webform.

Authorized Agents

In accordance with your relevant US Privacy Law, you may be able to designate an authorized agent to make a request on your behalf by selecting that option on the webform. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent‘s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request or ask you for any additional information that we consider necessary to verify you and/or your authorized agent’s identity.

Information Pertaining to Minors Under 16

Please contact us at [email protected] or on our webform to inform us if you have reason to believe that Acuant has collected information on an individual who is deemed a minor in your relevant jurisdiction. We only knowingly process minor information under our Identity Services as a service provider/processor and do not sell their personal information.

Appeals

If you are a resident of a US State that allows you to appeal a decision we have made in connection with your attempt to assert a right under applicable US Privacy Law, you may file an appeal of our decision by contacting us at [email protected]. Please ensure you provide us with the postal address in which you reside, accompanied with details for the basis of your appeal.

Your jurisdiction may allow you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request. For Virginia, you may do so by using the following: (www.oag.state.va.us/consumer-protection/index.php/file-a-complaint).

Updates To This US Notice

We will update this US Notice from time to time. When we make changes to this US Notice, we will change the "Effective Date" at the beginning of this US Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions in connection with this US Notice or other privacy-related matters, please use our webform or our toll-free number (+1 (833) 383-0085) to make your request.

Questions?

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