FORTIFI – California Consumer Privacy Act Policy
This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like FORTIFI that receive information from more than fifty thousand California consumers, to provide certain information to them. FORTIFI fully describes its practices to all its members and visitors in its Privacy Policy, but uses this separate notice to ensure that FORTIFI meets the CCPA’s requirements. This notice contains the following four parts:
- FORTIFI Does Not Sell Your Personal Information
- Your CCPA Rights
- The CCPA Categories of Personal Information FORTIFI Collects and the Sources
- The CCPA Categories of Personal Information FORTIFI Shares for a “Business Purpose”
1. FORTIFI DOES NOT SELL YOUR PERSONAL INFORMATION
The CCPA requires FORTIFI to disclose whether FORTIFI sells your personal information. FORTIFI does not sell your personal information.
2. YOUR RIGHTS UNDER THE CCPA
The CCPA provides Californians with the following rights:
2.1 Requests for Information
Like all of our members, you (or your authorized agent) can request a copy of your personal information. Authorized agents will be required to verify their identity. FORTIFI also will require members to confirm, by email from their primary account email address, that they granted the agent permission to submit the request. Under the CCPA, you can also request that FORTIFI disclose how it has collected, used, and shared your personal information over the past 12 months, including the categories of personal information FORTIFI collected and its purposes for doing so; the categories of sources for that information; the categories of third parties with whom FORTIFI shared it for a business purpose and its purposes for doing so. Companies that sell personal information (FORTIFI does not) must make additional disclosures.
If you are not a FORTIFI member, you can submit your request via an authorized agent. The authorized agent will be required to verify their identity, and you will be asked to confirm by email that you granted the agent permission to submit the request.
2.2 Your Right to Opt Out of Sales
FORTIFI does not sell personal information, so FORTIFI does not have an opt out.
2.3 Your Right to Notification
Under the CCPA, a company like FORTIFI cannot collect new categories of personal information or use them for materially different purposes without first notifying you.
2.4 Nondiscrimination for exercising your CCPA Rights
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
2.5 Your Right to Delete Personal Information
Like all FORTIFI members, you can request that FORTIFI delete your personal information by request or, if applicable, by closing your FORTIFI account. You also can request that FORTIFI delete specific information. FORTIFI honor such requests, unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when it is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
3. THE CCPA CATEGORIES OF PERSONAL INFORMATION FORTIFI COLLECT AND THE SOURCES
Our Privacy Policy describes the information FORTIFI collects and its sources. This notice organizes that information around the personal information categories set forth in the CCPA.
| CCPA Personal Information Category | Sources of this Information |
| Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers) | Information you provide directly or through your interactions with our Services (as defined in our Privacy Policy) or partners Vendors that provide information to help FORTIFI serve members relevant ads and understand the ads’ effectiveness Information from other FORTIFI members or customers |
| Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”) | Information you provide to FORTIFI directly and inferences FORTIFI makes based on that information Information from FORTIFI customers |
| Commercial information (e.g., information regarding products or services purchased, obtained, or considered) | Information you provide to FORTIFI directly, such as to buy a Premium service Your interactions with FORTIFI Services Information from FORTIFI partners and customers |
| Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services) | Your interactions with FORTIFI Your visits to third party sites that offer FORTIFI autofill, follow or “Apply with FORTIFI” functionality, as needed for fraud prevention and security purposes. |
| Geolocation Data | Information you provide to FORTIFI directly or through your interactions with our Services, as explained in the Privacy Policy |
| Professional or Employment-Related Information | Information you provide to FORTIFI directly Information from FORTIFI customers, partners, or from other members |
| Inferences | Information you provide to FORTIFI directly or through your interactions with FORTIFI Services Information from FORTIFI customers and partners |
| Personal information described in Cal. Civ. Code §1798.80(e)(such as name, address, telephone number, education, employment history, credit card or debit card number) | Information you provide directly or through your interactions with FORTIFI Services Information from FORTIFI customers or partners |
| Audio, electronic, visual or similar information | Information you provide directly or through your interactions with FORTIFI Services, customers or partners |
FORTIFI uses this personal information for the purposes outlined in our Privacy Policy.
4. THE CCPA CATEGORIES OF PERSONAL INFORMATION FORTIFI SHARE FOR A “BUSINESS PURPOSE”
While FORTIFI does not sell your personal information, FORTIFI may share it to support its operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, FORTIFI may share personal information at your direction, such as when you choose to communicate with other members through our Services.
4.1 Auditing Interactions
FORTIFI may share the types of personal information listed in Section 3 with partners, service providers and related companies, in order to audit interactions and transactions, such as to count or verify the positioning and quality of ad impressions.
4.2 Security Purposes
In order to secure FORTIFI Services, including to detect, prevent and investigate security incidents or violations of FORTIFI Professional Community Policies or applicable laws, FORTIFI may share the types of personal information listed in Section 3 with its partners, service providers, law enforcement and related companies.
4.3 Service Improvements
In order to improve FORTIFI Services (such as to identify bugs, repair errors or ensure that services function as intended) or conduct internal research and analysis to improve FORTIFI technology, FORTIFI may share the types of personal information listed in Section 3 with its partners, service providers and related companies
4.4 Service Providers and Other Notified Purposes
FORTIFI may share the types of personal information listed in Section 3 with Service Providers, as defined by the CCPA, in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).
