California Privacy Policy

PosiGen California Privacy Policy 

Last Updated: September 27, 2023

Your privacy is important to us at PosiGen, Inc. and its affiliates and subsidiaries (“PosiGen,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act (“CRPA”) and implementing regulations.  

This California Privacy Policy (“Policy”) describes how we collect, use, share, disclose, retain, and secure the personal information we gather about you through our website, www.posigen.com (collectively, the “Site”), when you interact with us as a customer, or otherwise (collectively, the “Services”).  This Policy does not apply to information collected from employees, job applicants, directors, contractors, or others within the employment context.  Those individuals should review our Employee Privacy Policy for more information on their data collection and use.

We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.  

What Information Do We Collect?

The below examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.  

In the previous 12 months, we have collected the following categories of personal information:

Sources From Which Personal Information Is Collected

We collect your personal information directly from you, from your interaction with the Site, from publicly available sources, and from third parties which collect the personal information directly from you.  

Business or Commercial Purposes for Which Personal Information Is Collected

Your personal information is used for the following purposes:

• To present our Services and its contents in a suitable and effective manner for you and your device;
• To contact you to provide you with information or services that you request from us;
• To advertise opportunities, services, or special events that we think may be of interest to you;
• To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
• To carry out our obligations and enforce our rights arising from any contracts; and
• To notify you about any additions, upgrades, or changes in our services.

Third Parties with Whom Personal Information Is Disclosed, Shared, or Sold

In the preceding 12 months, we have disclosed the following personal information about consumers for business purposes:

• We disclose personal information in categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), and K (inferences) with service providers.
• We disclose content posted on our social media platforms (g., if a consumer “comments” on a story) with other consumers. Such posts may include personal information in categories A and B, but the content depends on the individual posts.
• We may share all of our information, including your personal information, with our subsidiaries and affiliates in connection with providing the Services to you or otherwise in connection with business operations.

In the preceding 12 months, we have shared for cross-contextual behavioral advertising the following the personal information in categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), and K (inferences). 

In the preceding twelve (12) months, we have not sold the personal information of any consumer for monetary consideration.  However, our use of cookies and other tracking technologies may be considered a sale of personal information under the CCPA.  Categories of personal information that we have sold under the CCPA include categories A (identifiers), B (personal), D (commercial), F (internet), G (geolocation), and K (inferences).  Categories of third parties to whom personal information is sold under the CCPA include data analytics providers and advertising and marketing providers.

You can opt out of our tracking technologies for analytics and advertising service providers by clicking the Your Privacy Choices link or by broadcasting the Global Privacy Control signal during your browsing session.  Please note that your use of our website will still be tracked by PosiGen and its service providers.

We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.

Individual Rights

1. Right to Know About Personal Information Collected, Disclosed, Shared, or Sold

You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties.  There are two types of Rights to Know requests that you can make:

1. Right to Know (Abbreviated Request):  If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
   1. Categories of personal information collected, sold, or shared;
   2. Categories of sources from which personal information is collected;
   3. Categories of third parties to whom the information is sold, shared or disclosed;
   4. Business or commercial purpose for collecting, sharing, or selling personal information; 
   5. Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
2. Right to Know (Specific Pieces of Information Request):  If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
   1. Specific pieces of personal information collected about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive.  You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know.  We will state in our response if an exception applies. 

1. Right of Deletion

You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request.  This right is subject to certain exceptions.  We will state in our response if an exception applies.

1. Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations.   

We recognize the Global Privacy Control.  Your browser must be able to support the Global Privacy Control (“GPC”) for us to recognize your opt-out preference signal.  Please note that opt-out choices may be stored via cookies.  If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.  

For more information, please visit our Your Privacy Choices page.

1. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law.  We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.  We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA. 

1. Right of Correction 

If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request.  Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.  

1. Right to Limit Use and Disclosure of Sensitive Personal Information 

If we process Sensitive Personal Information, we will only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes.  As such, we do not perform any processing for which a Right to Limit request is available. 

1. Submitting Requests

You can submit your request by visiting our Data Subject Request page or by toll-free phone at 1-888-939-4442.

1. Verifying Requests

To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the consumer to whom the request relates prior to processing the request.  To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records.  We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.  

Making a verifiable consumer request does not require you to create an account with us.  

We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request.  We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

1. Authorized Agents

You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”).  If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us.  Failure to do so may result in PosiGen denying your request. 

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@posigen.com or via phone at 1-888-939-4442.