Last Revised April 1, 2021

PRIVACY NOTICE

This Privacy Notice (“Notice”) by 19 Ideas, Inc. (“our,” “us,” or “we”) applies to each one of our users, customers and visitors (“you” or “your”), including those of whom are California residents. This Notice is part of our Privacy Policy. This Notice relates to our products and services, and it also relates to our website at www.19ideas.com, any other websites of ours, and any web portals, mobile applications and brick-and-mortar stores of ours (collectively, our “Platform”). This Notice explains how we collect, use, and share your personal information and how you may exercise your rights under the California Consumer Privacy Act (“CCPA”).

California Consumer Privacy Act
We have provided this Notice pursuant to the CCPA. In this Notice, we use the terms, “personal information,” “business purpose,” “deidentified,” “sell,” “service provider” and “aggregate consumer information.” These terms will have the meanings given to them in the CCPA. For the full text of the CCPA, visit https://leginfo.legislature.ca.gov/.

Meaning of Personal Information
According to the CCPA, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Deidentified information and aggregate consumer information are not personal information. We may create deidentified information and aggregate consumer information by removing identifiers from your personal information and satisfying the other requirements of the CCPA.

No Sale of Your Personal Information
We do not, and will not, sell any of your personal information.

How We Collect Your Personal Information
We may collect your personal information in a variety of ways, such as by:

automatically pulling data from your browser or device, such as your computer or smartphone, by embedding computer code or data files to track your activity or geolocation, by other tracking means or by the methods described in our Cookie Policy;
receiving information you have provided to us via phone, text, email, electronic message, online form submission or other communications;
communicating with you in-person; and
using the other methods described in our Privacy Policy.

The Categories of Your Personal Information We May Collect
The following table lists the categories of your personal information that we may collect for our business purposes:

Categories of Personal Information	Examples of Personal Information
Identifiers (if you chose to provide them)	Your name, unique personal identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, state identification card number, passport number, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, and any other of your financial information, medical information, or health insurance information.
Characteristics of Protected Classes (if you chose to provide them)	Your race, color, national origin, religion, gender (including pregnancy), disability, age and citizenship status.
Commercial Information (if you chose to provide it)	Your records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric Information (if you chose to provide it)	Photos, videos and images of you, including your face, eyes, fingerprints and voice.
Network Activity and Device Information	Your device, browser, internet or other electronic network activity information, including browsing history, search history, information regarding your interaction with an internet website, application, or advertisement, network routing information (where you came from), date/time stamps, clickstream information (when a webpage was visited and how much time was spent on the webpage), device information, browser type, Internet Protocol (IP) address (which may identify your general geographic location), referring/exit webpages, and number of visitors, views, and interactions.
Geolocation Data (if you chose to provide it)	Your general geographic location and your Internet Protocol (IP) address, which may identify your general geographic location.
Audio and Visual Information (if you chose to provide it)	Your audio, electronic, visual, thermal, olfactory, or similar information, including voices, sounds, photos and videos of you.
Professional Information (if you chose to provide it)	Your professional or employment-related information.
Education Information (if you chose to provide it)	If you are a student, your education information, personally identifiable information and directory information, such as education records, report cards, transcripts, disciplinary records, contact and family information, and class schedules.
Inferred Profile Information	Inferences drawn from any of the information described in this table to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

The Categories of the Sources of Your Personal Information
We may obtain your personal information from the following categories of sources:

Categories of Sources	Description
You	We may collect the content, communications and personal information you send or provide when you use our products, services or Platform.
Your Devices	We may pull your personal information from your devices and browsers through tracking methods and by placing cookies as described in our Cookie Policy.
Other People	We may receive your personal information from people who use our products or services, such as when people share or comment on a photo or video of you, send a message to you, or upload, sync, or import your contact information.
Service Providers	We may receive your personal information from our service providers. Our service providers may collect your personal information from you or your devices in accordance with their privacy policies and the CCPA. For example, our service providers may use Internet-based software that connects or links to our products, services or Platform. This may enable our service providers to collect your personal information.

Our Purposes for Using Your Personal Information
We may collect and use your personal information for the following purposes:

Necessary Purposes: Section 1798.105(d) of the CCPA describes personal information that may be necessary for us or our service providers to keep for conducting any of the activities specifically described in that Section (“Necessary Purposes”). We may keep and use your personal information for completing transactions with you, for providing you with our products or services, for performing a contract with you, and for the other Necessary Purposes.

Additional Purposes: We may use and share your personal information for the following additional purposes:
- planning and performing the marketing activities for our products, services and Platform;
- evaluating, improving, researching and developing our products, services and Platform; and
- our other business purposes.

If we use or share your personal information for the additional purposes described above, we will follow the requirements of the CCPA, including the restrictions on how our service providers can use and disclose your personal information.
The Categories of Third Parties Who May Receive Your Personal Information
We may share your personal information with the following categories of third parties:

Categories of Sources	Description
Connected People and Businesses	This includes people and businesses that own or operate apps, websites, products and services that are connected to our products, services or Platform.
Service Providers	This includes our service providers involved with our business purposes.
Law Enforcement Agencies	This includes law enforcement agencies concerning activity that that we reasonably, and in good faith, believe may violate federal, state, or local law.
Others Permitted by Applicable Law	This includes other third parties permitted to receive your personal information in accordance with the CCPA.

At your choice, others may receive your personal information, such as:

people and others to whom you share your personal information; and
people and others who receive your personal information from those who originally received it from you.

How to Exercise Your Rights Under the CCPA

Right to Request Details: You have the right to request the categories and specific pieces of your personal information that we have collected.

Right to Request Deletion: You have the right to request that we delete your personal information that we have collected.

Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

Request Method: To exercise your “right to request details” or your “right to request deletion,” please use our contact page.

Verifying Your Identity: To protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information, such as a government-issued ID. Under the CCPA, you may exercise these rights yourself, or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf, and we may need to verify your authorized agent’s identity.

Noteworthy Limitations: The CCPA does not require us to:
- provide personal information to the same requestor more than twice in a 12-month period;
- provide personal information that we collected more than 12 months before we received and verified your request;
- keep any personal information collected for a single, one-time transaction, if such information is not sold or retained by us;
- reidentify or otherwise link information that is not maintained in a manner that would be considered personal information; or
- delete any of your personal information that we keep for Necessary Purposes.