Privacy Policy for California Residents (CCPA)
Effective date: March 11, 2025
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.
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.
1.
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 last 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 <br>(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
2.
Use of Personal Information.
(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.
3.
Sharing Personal Information
|
Personal Information Category |
Category of Third-Party Recipients
|
|||
|---|---|---|---|---|
| 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 | ||
4.
Your Rights and Choices.
(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.
5.
Exercising Your Rights to Know or Delete.
6.
Response Timing and Format.
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.
7.
Personal Information Sales Opt-Out and Opt-In Rights.
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.
8.
Non-Discrimination.
(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.
9.
Other California Privacy Rights.
10.
Changes to Our Privacy Policy.
11.
Contact Information.
Email:
privacy@inveloapp.comPostal 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.