CCPA Privacy Notice

NAPCO Media, LLC Privacy Notice for California Residents
Effective: January 1, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS is a supplement to the information contained in the NAPCO Media, LLC. Privacy Policy (collectively, “we,” “us,” or “our”), as well as any other privacy notices we may provide, and applies solely to visitors, users, subscribers, members, and others who reside in the State of California (“Consumers” or “you”). NAPCO Media, LLC. has implemented this policy to comply with the California Consumer Privacy Act of 2018, as amended, and implementing regulations (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Policy.

The term Client is used throughout this policy and refers to our Advertisers, Partners, Affiliates, Branches, Sponsors, or others for whom we work with or partner with.

AInformation We Collect

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 device or an individual (“Personal Information”). Personal Information does not include (i) publicly available information that is lawfully made available to the general public by way of federal, state, or local government records; (ii) de-identified or aggregated consumer information; and (iii) information excluded from the CCPA’s scope, like: (a) 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) or clinical trial data, and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We have collected the following categories of Personal Information from Individuals within the last twelve (12) months:

Category CCPA Examples 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. Yes
Social Security number, driver’s license number, passport number, or other similar identifiers. No
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, description, address, telephone number, employment. Some Personal Information included in this category may overlap with other categories. Yes
A credit card number, debit card number, or any other financial information for a transaction Yes: Not stored
A passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information. No
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). No
D. Commercial information. Records of products or services purchased, obtained, or considered Yes
Records of personal property 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 Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 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

We obtain the categories of Personal Information listed in the table above from the following categories of sources:

We obtain the categories of Personal Information listed in the table above from the following categories of sources:

  • Directly from You. For example, (i) if you visit our websites, respond to a survey, participate in a telephone interaction, fill out a registration form or otherwise agree to become a Member (as defined in our  Privacy Policy ), (ii) if you fill out a form or communicate with us through one of our websites to receive information about our business to business services or to schedule a demonstration of our online, media, marketing, or data services products or programs, and (iii) if you expressed interest in being contacted by us at a trade show in which we participated or hosted.
  • Directly from our Clients or their agents.  For example, from documents or files that our Clients provide to us including, but not limited to, suppression lists/do not call lists and IP addresses corresponding to individuals who have either opted-out of Client communications or who have visited Client’s websites, or related to the products or services our Clients are purchasing from us.
  • Indirectly from our Clients or their agents.  For example, through information we collect from our Clients in the course of providing services to them.
  • Directly and indirectly from activity on our websites. For example, from observing your actions on our websites or through your submission of an online form requesting a demonstration or walkthrough for one of our products or services.
  • From Third Parties that contract with us or interact with us in connection with the services we perform. For example, from (i) vendors and partners that help us to build contact lists, supplement or update your information in our database, or confirm/verify our records and information are accurate and up to date, (ii) third parties that may contact you, on our behalf, to provide you relevant content and/or to become a member, or (iii) third parties (including, other B2B contact providers) that integrate their services with ours or provide us access to their services.

BUse of Personal Information

We may use, sell, or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us or our Service Providers with Personal Information as part of a telephone interaction, through completion and submission of an online registration form on a NAPCO Media, LLC. website, affiliate website, or vendor/partner website, or any other method or means of communication we will: (i) use that information to send you emails, newsletters, and other notices concerning our products or services, or news, that may be relevant to your professional interests, (ii) sell that information to our clients, partners, affiliates or third-parties, so they may contact you with information about, and invitations for, products and services tailored to your professional interests and responsibilities, or (iii) communicate with you, advertise to you or invite you connect with us or with your peers and with providers of technologies, goods, and services that may be relevant to your professional interests.
  • To provide, support, personalize, and develop our websites, products, and services.
  • To create, maintain, customize, and secure your member account with us.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience on our websites and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or telephone (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
  • As necessary or appropriate to protect the rights, property or safety of us, our members, Clients or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

CSharing or Selling of Personal Information

We may share your Personal Information with other parties, including Service Providers, for a business purpose or may sell your Personal Information to third parties, including our Clients, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose Personal Information to a Service Provider, we either enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract OR, we will make a list of such Service Providers we work with available to you.

1Sharing Personal Information for a Business Purpose

In the preceding twelve (12) months, NAPCO Media, LLC. has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

We disclose/share your Personal Information with the following categories of third parties for a business purpose:

  • Service Providers;
  • Affiliates;
  • Data aggregators;
  • Data hygiene and data cleansing providers; and
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

2Sales of Personal Information to Clients (Third Parties)

The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales. In the preceding twelve (12) months, NAPCO Media, LLC. has sold the following categories, or certain components of the following categories, of Personal Information to its Clients:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category D: Commercial Information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

We sell your Personal Information to the following categories of third parties:

  • Businesses (including our Clients/Partners); and
  • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

DYour 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.

1Access to Specific Information and Data Portability Rights

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 and confirm your verifiable request (see Exercising Access, Data Portability, and Deletion Rights), 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;
  • The specific pieces of Personal Information we collected about you (also called a data portability request); and
  • 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.

2Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained in our databases, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

  1. 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, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using one of the following options:

Only you or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable request related to your Personal Information.  You may also make a verifiable consumer request on behalf of your minor child, although we do not collect Personal Information of minor children.  We will use reasonable methods to verify your request including, for example, comparing the email address you used to register on a NAPCO Media, LLC. or affiliated third party website.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • 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.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4Response Timing and Format

We strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 the email address associated with 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 may only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. For data portability requests, we will work to 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.

We do not charge a fee to process or respond to your verifiable 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.

5Personal Information Sales Opt-Out and Opt-In Rights

If you are sixteen (16) years of age or older and a California resident, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). Our business, as a business-to-business (“B2B”) provider, is targeted to business professionals. Therefore, we do not collect or sell the Personal Information of individuals we know are less than sixteen (16) years of age.  If we learn that we have inadvertently collected the Personal Information of someone under the age of 16, we will immediately terminate the associated account and delete any data in connection with such registration and the user’s activity.

The law defines “sale” broadly and includes not just the exchange of money, but any transfer of personal information to a third party in exchange for “other valuable consideration.”  We do sell and/or transfer personal information to certain third parties in order to operate our business (for example, to market our products and services).  If you opt out, we will not transfer your information to any third party except as explained below, and allowed by law.

Any transfer of data to a third party may be considered a sale of data.  The law considers any other business a third party unless that business agrees to specific contractual provisions.  We try to get all of the businesses to whom we send information to add this specific language to their contracts with us.  If you opt-out of the “sale” of data, we will not be able to send data to some of our business partners.  That may mean that, after you opt out, you may not receive all of the marketing and other information you are accustomed to receiving from us.  If one of our critical partners cannot agree to the specific contract language, and is considered a “third party”, it is possible that some features of our website or other services may not work for you after you opt out.

California law prevents us from asking you to “opt in” for a year after you opt-out.  We are allowed to tell you, however, if a specific transaction requires a transfer of data to a third party.  We may alert you if a transaction requires a transfer to a third party so that you can opt in if you would like to continue with the transaction.

Individuals who opt-in to Personal Information sales may opt-out of future sales at any time.

Exceptions to the opt-out.  The law creates several exceptions that are important for you to know.

We are allowed to transfer data to a service provider even if you opt out.  The law does not consider that kind of transfer to be a sale.  A service provider is a business that agrees not to use your information for any purpose other than providing the services specified in our contract.  For example, we transfer data to business partners to provide data security and detect fraud.  Those businesses are service providers.  Therefore, even if you opt out, we will continue to transfer data to our service providers.

We are allowed to transfer your data to a third party where you direct the transfer or direct us to interact with the third party.  For example, if you direct us to use a specific payment method to pay for your order, even if you have opted out, we will still transfer the data necessary to process your order.

Collecting information and using it ourselves is not a sale.  Opting out of the sale of your data does not prevent us from continuing to collect and process your personal information.

The opt-out only applies to personal information.  This is information that is or is capable of being linked to you.  Personal information is information that is or is capable of being linked to you.  Opting out will not limit our transfer of anonymized data to third parties.

There are technical limits to our ability to identify data related to you and, if you opt out, to prevent the sale of that information to other parties.  Where we can reasonably determine that information relates to you and you have opted out, we will not sell it to third parties except as allowed by law.  However, we may not be able to determine that information relates to you.  In that case, the information may be sold to a third party.

Opting out of the sale of personal information will not prevent you from receiving marketing messages from us.  If you wish to unsubscribe from our emails, please follow the unsubscribe link in one of our emails.

In order to provide you with our services, it is necessary for us to provide and personalize ads, content, and communications based on your use of our websites, including with information regarding your interests and your online interactions. If you request that we “do not sell” your Personal Information, as described in this Privacy Notice for California Residents (and our Privacy Policy), you will not be able to use any services we offer that require the continued use of your business email address, such as maintaining your member account and providing you access to our free Premium Services. If you make this request, you will still be able to access all the information and content that we offer on our websites to non-members. Further, you may register a new account with our websites at any time using a new corporate email address.

Do Not Sell Option

If you would like to opt out of the sale of your data, you may:

You are not required to create an account in order to opt out.

ENon-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.  Unless permitted by law, 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.

FChanges to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

GContact Information and Accessibility

This notice can be made available in alternate formats upon request. If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 215-238-5300 | (800) 627-2689

Website:  www.napco.com

Email: datacompliance@napco.com

Postal Address:
NAPCO Media, LLC
1500 Spring Garden St, Ste 1200
Philadelphia, PA, 19130