California Notice

Collection of Information

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“personal information”).

We have collected the following categories of personal information from our California consumers within the last twelve (12) months (both online and offline):

Categories of Sources

We obtain the above categories of personal information from the following categories of sources:

• Directly from you
• Automatically collected information,
• Our business clients,
• Our service providers, and
• Information when you log in with a third party’s single sign-in.

Use of Information

We may collect or disclose your personal information for one or more of the following purposes:

• To operate the Site and Services,
• To conduct fraud protection, security, debugging activities in connection with the Site and our Services,
• To process transactions with you,
• To personalize the Site and Services,
• To respond to your inquiries,
• To send communications,
• To market and sell the Services,
• To manage users’ accounts,
• To bill for fees owed by business clients,
• To measure the success of campaigns and content,
• To resolve disputes,
• As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things), and
• As described to you when we collect your personal information or as otherwise permitted under the CCPA.

If we will collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, we will notify you.

How we Disclose your Personal Information

Disclosing Personal Information for a Business Purpose 

We may disclose your personal information to a third party for a business purpose. We ask these third parties to keep the personal information confidential and not use it for any purpose except to perform the Services.

We may disclose your personal information with the following categories of third parties:

• Our business clients, such as the brands you interact with our Services in connection with;
• Our service providers, such as:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.

• Parties You Authorize, Access or Authenticate, such as:
  
  • Third parties you access through the services.

We may also share your information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Lastly, we may share with or transfer your information to our affiliates, or a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data Retention 

We retain personal information about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or to perform our business or commercial purposes for collecting your personal information. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the personal information, why we collected the personal information, and the sensitivity of the Personal Data. In some cases we retain personal information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Sales of Personal Information 

In the preceding twelve (12) months, we have not “sold” your personal information as defined under the CCPA.

“Sharing” your Personal Information 

We will not share your Personal Data for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age for purposes of cross-contextual behavioral advertising.

We may incorporate Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. You can opt out of data sharing by following the instructions under “Your California Rights &Choices.”

We share Personal Data with the following categories of third parties:

• Business Clients
• Our Service Providers
• Parties You Authorize, Access or Authenticate

Your California Rights & Choices

The CCPA provides California residents with specific rights about their personal information.

Access

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 consumer request, 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 that personal information,
• The categories of third parties with whom we share that personal information, and
• The specific pieces of personal information we collected about you.

When we provide you with the specific pieces of personal information about you, you may copy that information and use it for your own purposes.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Deletion

You have the right to request that we delete any of your personal information that we collected from you and still retain. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless there is an exception to deletion that applies.

There may be circumstances where we do not delete your information or we delete only part of your information if keeping the information is necessary for us or our service providers to:

• Comply with a legal obligation.
• 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.
• Enable internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Help to ensure security and integrity to the extent the use of your personal information.
• Debug products to identify and repair errors that impair existing intended functionality.
• 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.
• Engage in scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws.
• To exercise or defend legal claims.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Exercise other exceptions or exemptions as provided by the CCPA.

Other California Rights

To exercise your rights to access, correct, or delete, please submit a verifiable consumer request to us by either:

• Emailing us at privacy@fuelcycle.com and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).
• Submitting a web form located here and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).

To exercise your right to opt out from “sharing” under the CCPA, you can submit a request to us by either:

• You can use a Global Privacy Control or similar control that is legally recognized by a government agency or other industry-accepted standard.
• You can contact our Privacy Team by emailing privacy@fuelcycle.com

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.

To exercise your rights with respect to personal information held by a business client of ours, you may contact that business client directly.

Response & Timing

We will respond to verifiable consumer requests within the time period required under the CCPA.

If you have an account with us, we may deliver our written response to that account, otherwise our response will generally be sent to your email address.

Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-discrimination

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that we receive from you.

Financial Incentives

We may offer certain financial incentives permitted by the CCPA that could result in different prices, rates, or quality levels. In such case, we will provide you with a notice of financial incentives that will 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.

Information We Collect from Resources

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a Resource in the course of the natural person acting in his/her capacity as a Resource (“personal information”), some of which may be considered sensitive under applicable law.

We have collected the following categories of personal information from our Resources within the last twelve (12) months (not all information may apply to you):

Use of Personal Information of Resources

We may use the personal information of our Resources for one or more of the following purposes:

• Employees: We may use your information for the following purposes (not all of these may apply to you): identifying you, verifying work authorization, administering taxes and health, medical and other benefit plans, keeping track of your records, contacting you, facilitating payment to bank accounts, contributing to and administering 401(k) plans, garnishing wages required by law, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
• Job Applicants: We may use your information for the following purposes: identifying you, keeping track of records, contacting you, evaluating your candidacy, performing background and reference checks, and onboarding you. See our general privacy policy for additional detail about job applicant data practices.
• Independent Contractors: We may use your information for the following purposes: identifying you, administering taxes, keeping track of your records, contacting you, facilitating payment to bank accounts, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
• Legal and Other Uses: We may also use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.
• We may use your information as described to you when collecting your personal information or as otherwise permitted in the CCPA.

The Company 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.

How we Disclose your Personal Information

Disclosing Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose. We ask these third parties to keep the personal information confidential and not use it outside of the business purposes for which we collected such information.

We may disclose your personal information with the following categories of third parties:

• Our business clients, for example, if you work on such client’s account;
• Our service providers, such as:
  
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Employments benefits providers.
• Parties You Authorize, Access or Authenticate, such as:
  
  • Third parties you access through your relationship with us.

We may also share your information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our systems; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Lastly, we may share with or transfer your information to our affiliates, or a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting requirements, or as necessary to resolve disputes.

Under some circumstances we may de-identify or aggregate  your personal information so that it can no longer be associated with you. We reserve the right to use such de-identified or aggregate data for any legitimate business purpose without further notice to you or your consent.

Data Security

We have implemented commercially reasonably appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.

Selling or “Sharing” your Personal Information

In the preceding twelve (12) months, we have not “sold” or “shared” your personal information as such terms are defined under the CCPA.

Response & Timing

We will respond to verifiable consumer requests within the time period required und the CCPA.