Privacy notice for California residents

This Privacy Notice for California Residents supplements the information provided by WizRocket Inc. doing business as CleverTap (“CleverTap,” “we,” “us,” “our,” or the “Company”) in the Company’s privacy policies.  This notice applies solely to all California resident CleverTap Website visitors; representatives or the Company’s vendors, business partners, and customers; users of the CleverTap services; end users of CleverTap customers’ websites and mobile applications whose personal information was collected by such customers; and others who reside in California (“California residents, consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

The Company provides its customers with a managed service providing them with the ability to analyze how their end users interact with customer website(s) or mobile application(s) and contact their end users via the Company’s website(s) and platforms (collectively, the “CleverTap Service”). Therefore, the CleverTap Service collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device (“personal information”). In particular, the CleverTap Service has collected the following categories of personal information from California residents within the last twelve (12) months:

The types of personal information CleverTap collects covered by this notice falls into four categories:

• “Website Visitor Information”: personal information collected from users visiting the CleverTap website.  Job candidates using the website to apply for jobs are examples of website information.  Job candidates may provide their contact information and resume (“Job Candidate Information”).
• “Account-Related Information”: contact information and biographical information about customers’ representatives and contacts used for marketing, opening new user accounts to use CleverTap’s services, and to maintain existing accounts.
• “Customer End User Data”: information and data collected via customers’ mobile applications and websites for processing by the CleverTap service.  This category may include behavioral data from the activities of end users using customers’ mobile applications and websites.
• “Other Personal Information”: contact information and biographical information about representatives of vendors, business partners, prospective customers, and others collected in connection with CleverTap’s business not falling within one of the previous categories.

Personal information, for purposes of this notice, does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • 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 Company obtains the categories of personal information listed above from the following categories of sources:

• Directly from your communications with us. For example, from forms you complete or products and services you purchase.
• Indirectly from you via collecting data from your use of a computer or mobile device. For example, from observing your actions via the CleverTap Service.
• From our customer business. For example, we receive contact information about a representative because another customer representative has supplied it to us.
• From third parties in connection with the performance and marketing of our Services.

More specifically, the table below summarizes the categories of sources for each type of personal information CleverTap collects.

Category of Personal Information	Applicable Categories of Sources
Website Visitor Information	Collection by direct communications from a website visitor. Personal information collection from website visitors’ computers or mobile devices.
Account-Related Information	Collection by direct communications from customers’ representatives. From a customer business.  One customer representative may supply personal information about other customer representatives.
Customer End User Data	Collection of personal information collection from a user’s computer when using customers’ mobile applications and websites.  Based on a customer’s configuration and use of the CleverTap service, CleverTap receives information about customers’ end users’ use of customers’ mobile applications and websites. CleverTap customers may supply CleverTap with additional personal information about their end users to supplement what the CleverTap service receives from end users’ use of customers’ mobile applications and websites.
Other Personal Information	Some individuals supply their contact information directly to CleverTap or its representatives. Representatives of our customers may supply us with information about other individuals with which CleverTap may do business. CleverTap may receive personal information about individuals from third parties.  One example is the collection of information from visitors to websites other than CleverTap’s website using one or more vendors of CleverTap providing analytics about website usage.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our CleverTap Service, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your CleverTap Service experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our CleverTap Service, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our CleverTap Service, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our CleverTap Service, products, and services.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

To understand the Company’s practices regarding the sharing or disclosure of personal information:

• See the CleverTap Website Privacy Policy regarding the personal information of website visitors;
• See the CleverTap Customer Data Privacy Policy regarding personal information of customers’ representatives and their end users.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you the information you have requested.  You may, under California law, request one or more of the following types of information:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  
  

Deletion Request Rights

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
8. Other exceptions provided under applicable law.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at security@clevertap.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Although California law requires businesses to give individuals a right to opt out of the sales of personal information and bars the sale of personal information of minors younger than 16 without affirmative authorization, CleverTap neither sells personal information nor has customers that are minors.  Accordingly, this set of rights does not apply to CleverTap.

We will not discriminate against you for exercising any of your CCPA rights. If a customer representative exercises rights under CCPA, we will not:

• Deny you goods or services to the customer.
• Charge the customer different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide the customer with a different level or quality of goods or services.
• Suggest that a customer may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, each customer must have at least one representative with which CleverTap can transact business.

California law requires online service providers to disclose in their privacy policies how they respond to “do not track” signals.  These signals are settings in browser software requesting that websites not track users’ activities.

There is no standard that governs what, if anything, websites should do when they receive these signals. Accordingly, CleverTap does not currently take action in response to these browser settings. If and when there are industry standard ways for responding to these signals, we may revisit our policy on responding to these signals.

Under California Business and Professions Code Section 22581, a business with actual knowledge that a minor has posted information to its website must allow minors with registered accounts with the business the right to request and obtain deletion of information they posted publicly with some exceptions. CleverTap does not allow minors to have registered accounts with its service and does not permit minors to use its website.

However, registered users of social media accounts may post information to CleverTap’s blogs.  Accordingly, although CleverTap may not be required to provide a right of erasure to minors, CleverTap will honor any requests from minors to delete any information they have posted on CleverTap’s blogs, which are publicly available.

Any such request should include a detailed description of the specific content or information to be removed. Please be aware that applicable law may permit or require CleverTap to retain some or all of your posted information on a publicly-available location.

The Company reserves the right to amend this Privacy Notice for California Residents at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the CleverTap Service and update the notice’s effective date. Your continued use of our CleverTap Service following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described below and in the Website Privacy Policy or Customer Data Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 415-513-5756

CleverTap Service: https://www.clevertap.com/contact-us

Email: security@clevertap.com

Postal Address:

WizRocket Inc.

Attn: Sunil Thomas

607 W Dana St. Suite A, Mountain View, CA 94041