Privacy Policy for California Residents (CCPA)

Effective date: January 25, 2022

This Privacy Policy for California Residents supplements the information contained in the Invelo Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("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 Policy.

Information We Collect. We collect certain information via this Website that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). For the purposes of this policy, “Personal Information” does not include publicly available information from government records or deidentified or aggregated consumer information. In particular, our Website collects the following categories of personal information directly from consumers, when they submit a form or establish a subscription to access our Service, and indirectly by observing consumers’ actions when visiting our Website:

Category	Examples	Collected
A. Identifiers	First and name, email address, street (billing) address, Internet Protocol (IP) address, account name, and other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES (Credit Card)
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial Data	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric Data	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	No
G. Geolocation Data	Physical location or movements.	No
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment data	Current or past job history or performance evaluations.	No
J. Non-public education information (per 20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Use of Personal Information. We may use or disclose the personal information we collect for one or more of the following purposes:

(a) 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 in connection with establishing a subscription to our service, we will use that information to process your payment and facilitate access. We may also save your information to facilitate new orders.

(b) To provide, support, personalize, and develop our Website and our Service.

(c) To create, maintain, customize, and secure your account with us.

(d) To process your requests, transactions, and payments, and prevent transactional fraud.

(e) To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

(f) To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including via email or text message (with your consent, where required by law).

(g) To help maintain the safety, security, and integrity of our Website, our Service, databases and other technology assets, and business.

(h) For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

(i) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

(j) As described to you when collecting your personal information or as otherwise set forth in the CCPA.

(k) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred.

We 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.
Sharing Personal Information. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. On an ongoing basis, the Company may disclose personal information for a business purpose to the categories of third parties indicated in the chart below. As of the date of this policy, we do not sell personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights (below).

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A. Identifiers	Select service providers (i.e., email service providers and payment processors	None
B: California Customer Records personal information categories.	None	None
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	None	None
E. Biometric Data	None	None
F. Internet or other similar network activity	Select service providers (i.e., web analytics service providers).	None
G. Geolocation Data	None	None
H. Sensory Data	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

Your 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.

(a) Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity see Exercising Your Rights to Know or Delete (below), we will disclose to you:

(i) The categories of personal information we collected about you.
(ii) The categories of sources for the personal information we collected about you.
(iii) Our business or commercial purpose for collecting or selling that personal information.
(iv) The categories of third parties with whom we share that personal information.
(v) If we sold or disclosed your personal information for a business purpose, two separate lists disclosing such 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.
(vi) The specific pieces of personal information we collected about you (also called a data portability request). We do not provide a right to know or data portability disclosure for B2B personal information.

(b) Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity see Exercising Your Rights to Know or Delete (below), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

(i) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
(iii) Debug products to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
(v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
(vii) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
(viii)Comply with a legal obligation.
(ix) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete. To exercise your rights to know or delete described above, please submit a request by completing the California Privacy Rights Request form or by sending an email to privacy@inveloapp.com. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must include sufficient detail to enable us to properly understand, evaluate, and respond to it, and must also include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include at least two (2) verifiable contact methods (phone, email, address, etc.).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. You do not need to create an account with us to submit a request to know or delete. 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 the request to verify the requestor's identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights (below).
Response Timing and Format. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@inveloapp.com. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 our receipt of your request. 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, specifically in the form of a .txt or .csv file.

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.
Personal Information Sales Opt-Out and Opt-In Rights. As of February 2, 2002, this company does not currently qualify as a covered business under the California Consumer Privacy Act (Cal. Civ. Code § 1798.140(c)(1)). At which point this company qualifies, you will have the right to direct us to not sell your personal information at any time (the "right to opt-out"). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request and will be provided a link to do this.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

(i) Deny you goods or services.

(ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

(iii) Provide you a different level or quality of goods or services.

(iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@inveloapp.com.
Changes to Our Privacy Policy. We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information. If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in our 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:

Email:
privacy@inveloapp.com

Postal Address:
Invelo, Inc.
Attn: Privacy Officer
90 Glenn Street, Suite 2
Lawrence, MA 01843

If you need to access this Policy in an alternative format due to having a disability, please contact admin@inveloapp.com.