As data experts, we understand that the ability to use and process consumer data can only occur in an environment where we earn the trust of both the companies on whose behalf we process customer data and the individuals to whom such data relates in order to deliver mutual value to both brands and consumers.
Privacy Statement – California
Last updated: July 9, 2021
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Within the last 12 months, we have collected the following categories of personal information from consumers, or have received the following categories of personal information from other businesses:
Category of personal information
(Note: These are examples of the category and not all of this data is collected)
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment.|
|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).|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|E. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|F. Geolocation data.||Physical location or movements.|
|G. Professional or employment-related information.||Current or past job history or performance evaluations.|
|H. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Personal information does not include publicly available information from government records, deidentified or aggregated consumer information.
We may disclose your personal information to other companies in our corporate group, affiliates and third parties to help us process your personal information for the purposes set out in this policy. When we disclose personal information for a business purpose, we enter a contract that describes the purpose of the processing and prevents the recipient from retaining, using or disclosing the personal information for any purpose other than performing the contract.
In all of the categories in Chart A above, we collect personal information about consumers to provide marketing, advertising and analytics services.
For example, this may include helping clients deliver online advertising campaigns to their customers, helping clients identify new customers that are similar to their existing customers, and helping clients understand more about their customers so that they can develop better products and advertising campaigns with those customers in mind.
In all of the categories in Chart A above, we collect or receive the categories of personal information from the following categories of data sources: (important to note, is that these companies collect the personal information directly from consumers).
We may share or sell this information in all of the categories in Chart A for the purposes outlined above. The categories of third parties that we may have sold or disclosed the personal information to is outlined in the chart below:
Category of Company Receiving Data
|Advertising/Marketing Companies||Companies that provide marketing services and advertising services both online and offline. Typically, these companies are using the data to improve marketing relevance for consumers.|
|Apparel & Accessory Companies||Retailers and other merchants that typically sell clothing, shoes and fashion accessory products.|
|Automotive Companies||Car companies or companies that provide services for cars and trucks such as sales, car service, or car products.|
|Business to Business Companies||Companies that provide products and services for other businesses such as computer services, paper, and other products or services.|
|Parenting Product Companies||Retailers and other merchants that typically sell children’s products including clothing, shoes, toys, and other products.|
|Communication Services Companies||Companies that provide services such as home phones, cellular phones, TV services, and satellite service.|
|Consumer Packaged Goods Companies||Retailers and other merchants that typically sell groceries and other household products such as cleaning supplies.|
|Consumer Services Companies||Companies that provide consumer and residential services including storage, lawn care, home security.|
|Data Compiling Companies||Companies that purchase data from other companies and organize the data into descriptive categorizations for use in marketing activities.|
|Educational Institutions & Companies||Organization and companies offering education services including colleges, training centers and certification programs|
|Electronics Companies||Retailers and other merchants that typically sell electronics such as computers, TV’s, phones and other electronic products.|
|Energy and Utility Companies||Companies that provide residential energy and water services.|
|Financial Services Companies||Companies that provide financial services for consumers – note no credit information, bank information, or social security numbers are ever collected or used.|
|Food & Beverage Companies||Retailers and other merchants that typically sell food and beverage products such as meat, vegetables, and wine.|
|Gift Product Companies||Retailers and other merchants that typically sell gift products such as flowers, gift baskets, and other similar products.|
|Public Institutions||Organizations supporting consumer interests through public programs, government programs, and other related activities.|
|Health Product Companies||Retailers and other merchants that typically sell health related products such as vitamins, supplements, and other related products. Note: no medical data, insurance data, or prescription data is ever collected or used.|
|Lifestyle & Interest Product Companies||Retailers and other merchants that typically sell specialized products for hobbies, sports, fitness, wellness, and other lifestyle related activities.|
|Manufacturing Companies||Companies that produce consumer products for distribution through retailers and other merchants.|
|Not for Profit Organizations||Not for profit companies such as Charities and Political groups that collect donations from consumers for a specific cause.|
|Publishing Product Companies||Companies that create and sell products including magazines, books, newsletters, and newspapers.|
|Technology/Computer Software Companies||Companies that provide computer related products such as computer hardware and software, web and smart phone applications|
|Telecommunications Companies||Companies that provide services such as home phones, cellular phones, TV services, and satellite service.|
|Travel, Leisure & Entertainment Companies||Companies that provide services or products related to travel and entertainment including hotels, airlines, cruises, show tickets and other similar items.|
In the preceding twelve (12) months, we have sold personal information in all of the categories listed in chart A above. We do not sell personal information of persons under age 18.
The CCPA provides consumers (California residents) with specific rights regarding their personal information, these are explained below.
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. Once we receive your request, we will disclose to you:
You have the right to direct us to not sell your personal information (also referred to as the right to opt out). Once we receive your request, we will not include your personal information in any further sales unless you subsequently provide express authorization for us to do so. Our interactive form to submit your request can be found here or call us at the following toll-free number: 866-275-4526. We will respond to your request to opt-out within 15 days.
You have the right to request that we delete any of your personal information that we collected directly from you and retained. We may deny your deletion request if it is necessary for us or our service providers to retain your personal information, based upon allowed exceptions. Once we receive and verify your request, and no exception applies, we will delete and direct our service providers to delete your personal information as requested. We will contact you to confirm the deletion and the manner in which it was deleted. Please click here to make a deletion request.
We will not discriminate against you for exercising any of your rights under the CCPA.
To exercise the rights described above please submit your request to us by either:
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.
For the purpose of verification, we may request further information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.
Upon receiving a verifiable consumer request, we aim to deliver the required information within 45 days. Where we require more time (up to a further 45 days), we will inform you of the reason and extension period.
If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at the following address: DoNotMail@Choreograph.com
Consumer Right’s Request Summary
Requests to know complied with: 51 total, 28 complied with, 23 denied
Requests to delete complied with: 26 total, 24 complied with 2 denied
Requests to opt out of sale complied with: 2508 complied with, no denials
Median number of days to comply with: request to know – 1; requests to delete: 0 (immediate); requests to opt out: 0 (immediate covers both types).