Your California Privacy Rights & California Consumer Privacy Act Statement
Effective Date: January 1, 2020
If you are a California consumer, the information below may apply to you. Certain terms used in this section have the meaning given to them by the California Consumer Privacy Act (“CCPA”).
Collection and Disclosure
During the 12-month period prior to the effective date of this Statement, we may have:
- a. Collected the following categories of personal information about you:
- Identifiers: such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, signature, and other similar identifiers;
- Financial, Medical or Health Information: such as insurance policy number, bank account number, credit card number, debit card number, medical information, and health insurance information;
- Characteristics of Protected Classifications Under California or Federal Law: such as age and gender;
- Commercial Information: such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
- Biometric Information;
- Internet and Other Electronic Network Activity Information: such as browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
- Geolocation Data;
- Sensory Information: such as audio, electronic, and similar information; and
- Profile Inferences: such as inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- b. Collected personal information about you from the following categories of sources:
- From you or your device, for example, through your use of our website and apps (GreatCall Link and Lively by GreatCall), when you register for a GreatCall account on mygreatcall.com, make a purchase, participate in promotional activities, sign up for our newsletters or email lists, participate in a product review or survey, or otherwise contact or communicate with us via mail, email, or fax;
- An authorized family member or care giver to purchase or activate GreatCall products and services for you;
- Representatives of the care facility where you reside, your managed care organization, and other commercial partners;
- GreatCall affiliates;
- Retail businesses that sell GreatCall products or services;
- Our business partners; and
- Advertising networks and third-party joint marketing partners.
- c. Collected personal information about you for the following business or commercial purposes:
- Performing services, including maintaining or servicing accounts (e.g., your GreatCall account), providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undertaking internal research for technological development and demonstration;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
- Complying with and enforcing applicable legal requirements, relevant industry standards and our policies.
- d. Sold (as defined under California law) the following categories of personal information:
- Identifiers (online) associated with a device used to interact with our digital properties or advertisements (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology); and
- Internet and other electronic network activity information associated with a device used to interact with Digital Properties or advertisements.
We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.
We do not sell personal information as the term is traditionally understood, versus the definition under the CCPA—for example, we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us.
- e. Shared your personal information with the following categories of third parties: vendors who provide services on our behalf; our joint marketing partners; our affiliates; our business partners; and government entities, including law enforcement.
- f. Disclosed for a business purpose the following categories of personal information about you: identifiers; customer record information; financial, medical, or health information; characteristics of protected classifications under California or federal law and profile inferences; internet and other electronic network activity information; commercial information; biometric information; geolocation data; sensory information; and profile inference.
California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information related to you we have collected during the past 12 months. This may include
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected or sold the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose
- Deletion: You have the right to request that we delete certain personal information we have collected from you. Exceptions apply.
- Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
- Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
- To request a report regarding your personal information collected during the preceding 12 months, please click on the following link Access My Data.
- To make a deletion request, please click on the following link Delete My Data.
- To submit a Shine the Light Request, please contact us via email through our Contact Us page or write to us (with a reference to CA Shine the Light Request) at
10945 Vista Sorrento Pkwy, Suite 120
San Diego, CA 92130
How to Submit a Request.
You also may request a report or make a deletion request by calling (800) 358-9307.
More information on opting out of the sale of your personal information is available here: Do Not Sell My Personal Information
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us, or do not log in to your account when submitting a request, we seek to collect the following information: name, email address, phone number, and postal address. If you own a GreatCall device, we may ask that you verify your identity by contacting us with that specific device. We reserve the option to require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
If you choose to exercise any of your rights under the CCPA, you have the right not to receive, and will not receive, discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. Employees, job applicants, and contractors are provided CCPA notice via a different statement.