California Consumer Privacy Act (CCPA)
Effective Date: July 24, 2020
Last [Updated/Reviewed] on: May, 14, 2023
Information We Collect
We, through our website, 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, We collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, Internet Protocol address, email address.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, address, credit card number, debit card number, or any other financial information, medical information. |
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), medical condition.||YES|
|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|
|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|
Live Well Zone obtains the categories of personal information listed above from the following categories of sources:
- through forms.
- product purchases.
- the consumer directly.
- advertising networks.
- internet service providers.
- data analytic providers.
- operating systems and platforms.
Use of Personal Information
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 age group or health condition in response to one of our email surveys, we will use that information to send you educational content and offers that are relevant only for your medical condition or age group. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate and/or speed up new product orders or process returns.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- The reason why your personal information was collected when you provided it to us.
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
If necessary to carry out a business purpose, we may share your personal information by disclosing it to a third party. 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, Live Well Zone has disclosed personal information for a business purpose [to the categories of third parties indicated in the chart below].
We share personal information to third parties, subject to your right to opt-out of those sales. Our personal information sales does not include information about individuals we know are under age 16. In the preceding twelve (12) months, Live Well Zone has shared the following categories of personal information [to the categories of third parties indicated in the chart below].
- Advertising networks
- Service providers
- Data analytics and providers
- Operating systems and platforms
- Social networks
- Data brokers or aggregators
- Internet cookie data recipients (i.e. Google Analytics, Facebook pixel)}
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|B: California Customer Records personal information categories.||Facebook|
|C: Protected classification characteristics under California or federal law.||Convertkit||None|
|D: Commercial information.||None||None|
|E: Biometric information.||None||None|
|F: Internet or other similar network activity.||Google|
|G: Geolocation data.||Convertkit|
|H: Sensory data.||None/[THIRD-PARTY CATEGORIES]]||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|
Reselling Personal Information
Under the CCPA, a third-party is prohibited from reselling personal information unless you, as the individual about whom the personal information is, were given explicit notice and proper opportunity to opt-out of further sales.
Deidentified Patient Information- HIPPA Compliance (include this section if HIPPA is essential for your business, i.e. you’re in a medical field)
We do not sell and/or disclose deidentified patient information exempt from the CCPA to third parties.
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
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. This right under the CCPA is the Right to Know. Once we receive your request and confirm your identity, 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).
Data Portability must be maintained, which is also a right under CCPA as amended. This means that the information that is provided as a result of data requests must be in a readily usable format.
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, we will review your request to see if any exceptions apply that would permit us to retain the collected information. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to locate and fix errors that impair existing intended functionality and purpose.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
The Right to Correct Inaccurate Personal Information
Under CCPA, as amended by CPRA, you have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Limit the Use of Sensitive or Personal Information
Under the CCPA, as amended by the CPRA, consumers also have the right to limit the use of the collected sensitive or personal information on them to the particular purposes and categories that the business collected the information for.
Right to Non-Discrimination for Exercising CCPA Rights
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted 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. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Required Notices at Collection
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either emailing us at [email protected].
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child (age 13 or younger) by emailing us at [email protected].
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:
- [SPECIFY WHAT VERIFICATION REQUIREMENTS YOU WANT to be SUBMITTED].
- [PARENT OR GUARDIAN VERIFICATION REQUIREMENTS]
- 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.
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 email us at [email protected].
If your identity and request were verifiable, then we will respond within forty-five (45) days of the receipt of the request. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically 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 usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically a 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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old[, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old]. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell My Personal Information.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by emailing us at [email protected]
If you have any questions or comments about this notice, about the way we collect information and the type of information we collect, please do not hesitate to contact us at:
Email: [email protected]