Supplemental California Consumer Privacy Act Privacy Policy

The CCPA requires SmallHD to provide certain information about our data processing practices to California residents in addition to the disclosures in our privacy policy and other privacy notices provided to California residents at or before the point of collecting personal information. If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Policy.  You can download a PDF version of the policy here:

1. Scope

In this Supplemental CCPA Privacy Policy, SmallHD provides disclosures for the 12 months preceding January 1, 2020, as required by the CCPA with respect to California residents. 

For clarification and without limitation, the CCPA provides that for the 12-month period preceding January 1, 2021, these disclosure requirements do not extend to:

(i) personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business; personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; or personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits (“HR Exemption”), or

(ii) California residents who are not acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency (a “Business Representative”) where SmallHD holds personal information reflecting a written or verbal communication or a transaction between SmallHD and the Business Representative and the communications or transaction with SmallHD occur solely within the context of SmallHD conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency (“Business-to-Business Exemption”).

California residents have certain rights under the CCPA as further described in this Supplemental CCPA Privacy Policy. The CCPA provides that until January 1, 2021, the described rights do not extend to the HR Exemption or Business-to-Business Exemption.

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

This Supplemental CCPA Privacy Policy describes the personal information we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to 

Line	Category	We collected such personal information to use for the following business or commercial purposes:	We have collected such personal information from the following categories of sources:	We shared such personal information with the following categories of third parties:
1.	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, device information (including operating system type, device identifiers, browser type, device type, domain name, access times, visit duration), usage data related to our website and services, data from our mobile apps (contact details, geographic location), live chat data, cookies and other data collection technologies.	Provide and improve services, authenticate for service access, fraud detection and prevention, security, troubleshoot, event planning and hosting, communicate with you, provide materials you request, provide chat functionality on our website, to follow up with you upon your registrations for services, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners, and to advertise to you through third party publishers.	Directly from you, from partners, and service providers.	Our service providers including our CRM service provider and data analytics providers, social networks, SmallHD affiliates and subsidiaries, partners, to third parties subject to compelled disclosures, and to payment processors.
2.	Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.	See above in line 1, as applicable.	See above in line 1, as applicable.	See above in line 1, as applicable.
3.	Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	To send you relevant information about us, our affiliates, and partners, to advertise to you through third party publishers.	Directly from you, from business data resellers, partners, and service providers.	Our service providers including our CRM service provider and data analytics providers, social networks, SmallHD affiliates and subsidiaries, partners, to third parties subject to compelled disclosures, and to payment processors.
4.	Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with our website, application, or advertisements.	See above in line 1, as applicable.	Directly from you, from service providers.	Our service providers including our CRM service provider and data analytics providers, social networks, SmallHD affiliates and subsidiaries, partners, to third parties subject to compelled disclosures, and to payment processors.

know”). To submit a request to exercise the right to know, please call our toll-free phone number 1-888-941-2111 or submit an email request to privacyinfo@creativesolutions.io and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

Our Personal Information Handling Practices in 2019

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.

Disclosure or Sale of Personal Information

Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. 

We do not and will not sell California residents’ personal information. 

We do not sell the personal information of minors under 16 years of age without affirmative authorization. 

3. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to privacyinfo@creativesolutions.io and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

4. Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.

5. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.

6. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 2 and 3 above:

• Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to SmallHD, Inc., Attention: General Counsel, 8 Mason, Irvine, CA 92618; and
• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

7. Contact for More Information

If you have questions or concerns regarding our privacy policy or practices, you may contact us using the following details:

Email address: privacyinfo@creativesolutions.io
Postal address:  SmallHD Attention: General Counsel, 301 Gregson Dr, Cary, NC 27511 USA