Effective Date: April 8, 2022
This California Privacy Notice (“Notice”) is a supplement to Greylock Holdings LLC d/b/a Wealthion (“Wealthion” “us” “we” “our”) other privacy policies or notices. In the event of a conflict between any other Wealthion policy, statement, or notice and this Notice, this Notice will prevail as to California residents and their rights under California law.
THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
In accordance with the CCPA’s requirements, this Notice describes our Collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) during the preceding twelve months, as well as the rights California Consumers have under the CCPA. Terms defined in the CCPA that are capitalized in this Notice have the same meanings as in the CCPA unless otherwise stated.
Consistent with the CCPA, job applicants, current and former employees and contractors, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered Consumers for purposes of this Notice or the rights described herein.
- Collection and Use of Personal Information
We Collect and share PI about California Consumers as described in the table below.
|Category||Examples of PI Collected||Categories of Recipients|
|Identifiers||Identifiers such as those enumerated below, or other similar identifiers, based on your usage of our services.|
|Automatically collected for all users: online identifier, internet protocol address||Service providers such as analytics and/or advertising platforms, fraud prevention services, cloud services and hosting providers, our CRM/CDP systems, and other similar vendors|
|As you provide information to use certain features of our services: real name, alias, postal address, email address||Service providers such as analytics and/or advertising platforms, our CRM/CDP systems, email marketing providers, direct mail marketing providers, and other similar vendors|
|If you choose to open an account with us, additional information as required to identify you and/or comply with other regulatory requirements: account holder name, social security number or tax identification number, driver’s license number, passport number||Services used to verify your identity for compliance purposes, fraud prevention, e-signature collection, and other similar purposes|
|Customer Records||If you choose to conduct a transaction with us, the following information may be provided by you: telephone number, tokenized instances of payment card details, tokenized instances of bank account details, bank account routing and/or account numbers, cryptocurrency wallet/payment address||Service providers such as payment processors, fraud prevention, the trust company that custodies your account, or similar vendors|
|Protected Characteristics||Marital status or familial status||Service providers such as the trust company that custodies your assets|
|Commercial Information / Purchase Details||Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Service providers, such as companies who provide fraud prevention services and services that you request like storage or shipping|
|Internet Usage Information||Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.||Service providers such as analytics and/or advertising platforms, fraud prevention, and other similar vendors|
|Geolocation Data||Only when you approve such requests: Precise physical location or movements and travel patterns.||Service providers, including for e-signature collection, fraud prevention, and other similar services|
|Sensory Data||Audio recordings of customer service calls.||Service providers who help us improve our customer interactions|
|Inferences from PI Collected||Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. This could commonly take the form of customer profiles reflecting preferences and predispositions.||Service providers such as our CRM/CDP systems, advertising platforms, and other similar vendors|
We Collect PI directly from the Consumer (e.g., when you complete an order, create an account, or request information from us), indirectly from the Consumer (e.g., through user activity on our website), from other individuals (e.g., when friends or family place a gift order or book a trip or class), and through customer service call recordings.
We Collect PI for the following business purposes:
- Providing our services, including maintaining and servicing your accounts, verifying your information, billing and processing payments, marketing, analytics services, and similar functions and services;
- Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
- Troubleshooting our services to identify and repair issues;
- Internal research and development;
- Quality and safety assurance, and improving, upgrading, and enhancing our products and services; and
- Processing and managing interactions and transactions for our products and services.
In addition, we may Collect, use, and disclose your PI as required or permitted by applicable law, when requested or compelled by law enforcement or legal process, for required tax reporting, or in connection with contractual obligations. We do not treat deidentified data or aggregate consumer information as PI, and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information.
Subject to the CCPA’s restrictions and obligations, our service providers and business partners also may use your PI for some or all of the above-listed business purposes (including to facilitate interest-based advertising and other advertising and marketing).
CCPA PRIVACY RIGHTS
Under the CCPA, California Consumers have certain rights which they may exercise independently or through an Authorized Agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify that the requestor is the Consumer about whom we Collected PI.
Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI. Accordingly, we will not include such information in response to Consumer requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.
Your California Consumer privacy rights are described below. To make a request, you may email us at email@example.com or call us at [insert brand toll-free and toll numbers – TOLL FREE REQUIRED]. In making a request, you will need to verify that you are the authorized user of the subject email address/account and that you are a current resident of the State of California. Please follow the instructions on our website and promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards. An Authorized Agent may submit a request on behalf of a Consumer if the Consumer has provided the Authorized Agent with power of attorney in accordance with California law; alternatively, we will (1) require the Authorized Agent to present verifiable written authorization from the Consumer that the Authorized Agent has the Consumer’s permission to submit the request; and (2) independently verify the Consumer’s own identity with us.
We may Collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with Consumer requests to the extent that doing so would infringe on our, or any other person’s or party’s rights, or conflict with applicable law.
You have the right to request that we disclose your PI that we have Collected and are maintaining for the 12-month period prior to your request date. Consumer requests of this nature may be made no more than two times in a 12-month period.
- The categories of PI we have Collected about you.
- The categories of sources from which we Collected your PI.
- The business or commercial purposes for Collecting or Selling your PI.
- The categories of third parties with whom we have shared your PI.
- The specific pieces of PI we have Collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will also list the categories of third parties to which we Sold PI, by categories of PI Sold for each Third Party.
You have the right to make or obtain a portable copy, no more than twice in a 12-month period, of your PI that we have Collected in the period that is 12 months prior to the request date and are maintaining. Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
“Do Not Sell” Rights
We do not sell California Consumer PI, including PI of minors under the age of 16, as “sell” is defined under the CCPA.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have Collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.
Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the online service, can request removal by contacting us firstname.lastname@example.org detailing where the content or information is posted and attesting that you posted it. We will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.
For more information regarding your California privacy rights, you may email us at email@example.com or write us at:
ATTN: Privacy/Legal & Compliance
New York, NY 10017