Last modified: 1 September 2021
When we use the term “personal information” in this CA Policy, we mean 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 or household. For the purposes of this CA Policy, personal information does not include:
- Publicly available information from government records;
- De-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer;
- Information excluded from the CCPA’s scope, such as:
- 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;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our employees, contractors and other Flourish Labs personnel, including crisis personnel.
Collection, use and sharing of Personal Information
We do not sell personal information.
In the last 12 months, we have collected the following categories of personal information:
- Identifiers, such as your name and email address;
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your phone number;
- Internet/Network Information, such as device information, logs and analytics data;
- Characteristics protected by law; for example, you might provide your gender as part of a research survey for us;
- Geolocation data, such as your location based on your IP address;
- Sensory information, such as recordings of any phone calls between you and Flourish Labs
- Other Personal Information, including information you submit into the feedback form and any communications between you and Flourish Labs; and
- Inferences we make, such as likelihood of retention or attrition.
Your California privacy rights
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
How to exercise your California consumer rights
To exercise your Right to Access, Right to Know or your Right to Deletion, please submit a request by emailing us at firstname.lastname@example.org with the subject line “California Rights Request”, or by filling out the “California Consumer Rights Request Form” below.
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last interaction with customer service.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Policy where we can verify the authorized agent’s authority to act on your behalf.
For requests to know or delete personal information, we require the following for verification purposes: 1) a power of attorney valid under the laws of California from you or your authorized agent; or 2) sufficient evidence to show that you have: provided the authorized agent signed permission to act on your behalf; and verified your own identity directly with us pursuant to the instructions set forth in this CA Policy; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Children under 16
Updates to this CA Policy
We will update this CA Policy from time to time. When we make changes to this CA Policy, we will change the date at the beginning of this CA Policy. If we make material changes to this CA Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.