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California Privacy Policy

SIMPLE TEEN SUCCESS PRIVACY POLICY

FOR CALIFORNIA RESIDENTS

Effective Date: July 28, 2023

Last Updated/Reviewed on: July 28, 2023

 

This¬†Privacy Policy for California Residents¬†supplements the information contained in the general¬†Privacy Policy¬†of Teen Success, LLC (‚ÄúSIMPLE TEEN SUCCESS‚ÄĚ) and applies to your use of our website found at¬†www.simpleteensuccess.com¬†(the ‚ÄúSite‚ÄĚ) and is solely applicable to¬† 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.¬†

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

 

Information We Collect

Our Site may collect information 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"). Personal information 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), clinical trial data, or other qualifying research data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, our Site has collected the following categories of personal information from consumers within the last twelve (12) months: 

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Yes.  Only names (real or alias), email address, IP Address, and general geographic location.

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.

NO (but third-party service providers have access to some information in this category).

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).

Marital status is indirectly collected as the result of sign-up/identification of parents.

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

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.

YES

G. Geolocation data.

Physical location or movements. 

Yes.  General geographic analytics.

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (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



Our Site obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete, your subscription and account, or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Site.

 

Use of Personal Information

We do not sell personal information that we may collect.

We may use or disclose the personal information we collect for one or more of the following 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 may use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we may 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 Site, products, and services.
  • To create, maintain, customize, and secure your account with us, if one has been created.
  • 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 Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, 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 Site, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • 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 Site users 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. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.

We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales

A: Identifiers.

Only to third-party service providers for operation of Site as stated in this policy.

None

B: California Customer Records personal information categories.

Only to third-party service providers for operation of Site as stated in this policy.

None

C: Protected classification characteristics under California or federal law.

Only to third-party service providers for operation of Site as stated in this policy.

None

D: Commercial information.

None

None

E: Biometric information.

None

None

F: Internet or other similar network activity.

Only to third-party service providers for operation of Site as stated in this policy.

None

G: Geolocation data.

Only to third-party service providers for operation of Site as stated in this policy.

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.

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), we will disclose to you:

  • 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.
  • 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.¬†
  • 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.

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), 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: 

  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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. 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 either:

  • Calling us at 1 (254) 645-8336
  • Emailing us at¬†[email protected].
  • Sending your request to us via mail at the address set forth in this Policy.¬†¬†¬†

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, you may send us notice of your designated authorized agent in writing. 

You may also make a request to know or delete on behalf of your child by sending us notice of your request in writing.   

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide 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:
    • Your full legal name, mailing address, email address, and other contact information, and at least one document verifying your identity.
    • In the case of a parent or guardian of a minor child, you provide your and your child‚Äôs full legal names, mailing address, email address, and other contact information, and at least one document verifying your identity and evidencing that you are the parent or guardian of the minor child about whom you are contacting us.
  • 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. 

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.

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 via email or phone (see our Contact information set forth in this Policy).  

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.

We will deliver our written response by mail or electronically (email), 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.

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

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We presently do not sell the personal information of consumers regardless of age.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permied by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • 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. 

 

CCPA Rights Request Metrics

Metrics regarding the consumer rights requests we received from California residents from January 1, 2023 to December 31, 2023 appear in the following chart:

   

Request Type

Received

Granted (in whole or in part)

Denied

[Median/Mean] Days to Respond

Requests to Know

0

0

N/A

N/A

Requests to Delete

0

0

N/A

N/A

Requests to Opt-Out of Personal Information Sales

0

0

N/A

N/A



Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section ¬ß 1798.83) permits users of our Site 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¬†[email protected].

 

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 Site and update the notice's effective date. Your continued use of our Site 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 SIMPLE TEEN SUCCESS collects and uses your information described here and in the 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 (254) 645-8336

Email:
[email protected].

 

Postal Address: 
Teen Success, LLC
Attn: Privacy Officer
4101 W. Green Oaks
Suite 305-339
Arlington, Texas  76016
[email protected]¬†
254-645-8336

 

If you need to access this Policy in an alternative format due to having a disability, please contact Teen Success, LLC at¬†[email protected]¬†and/or call us at¬†(254) 645-8336.