Updated August 9, 2020 HelloConvo LLC (“HelloConvo”) owns and operates the HelloConvoTM Influencer Marketing Platform (the “Platform”), an online marketing platform that connects leading brands with influencers/content creators (the "Platform Services"). Access by California residents to the Platform, www.helloconvo.com and/or any website owned, controlled or managed by Hello Convo, whether currently available or made available in the future (collectively, the “Sites”), and any features, is made available under this California Privacy Notice (which supplements our Privacy Notice), and the Terms of Service. The following details our California Privacy Notice (the “Notice") for the Sites and describes the types of information we gather from those persons visiting the Sites and how we use such information. We understand the importance of privacy and, accordingly, treat all information received in a responsible manner. This Notice applies to all of the services offered by HelloConvo and its subsidiaries and affiliated entities (the “services” or the “Services”) on the Sites. By accessing the Sites, you agree to be bound by the Notice. If you do not agree to the terms of this Notice, you will not be permitted to use the Sites. HelloConvo’s Privacy Notice Please follow the links below to review HelloConvo’s general Privacy Notice and Terms of Service. Capitalized terms herein have the same definition as set forth in the below links. Any conflict in language between these three documents is governed by this Notice. I. Notice at the Point of Collection of Personal Information HelloConvo may collect two types of information from California users of our Sites: “personal information” (such as name, e-mail address, mailing address, phone number, etc.) and “aggregate information” (such as frequency of visits to any of the Sites, search terms entered, Site pages most frequently accessed, browser type, etc.). We use this information in an effort to improve your experience on the Sites and to communicate with you about information that you request. We may also use this information to help us target specific services or offers to you, to contact you for troubleshooting purposes, to help us develop and improve our Sites, and to tailor our Sites to your interests.
Categories of Sources
We obtain the categories of personal information listed herein from the following categories of sources:
Directly from our customers or their agents. For example, from documents that our customers provide to us related to the services for which they engage us.
Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
Directly and indirectly from activity on our Sites (including submissions through our website portal, data collected from connected websites, or website usage details collected automatically).
From third-parties that interact with us in connection with the services we perform.
Collecting and Using Your Personal Information for Business Purposes
HelloConvo collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Social media accounts, handles, avatars, and images.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, date of birth, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
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).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Information related to current or past campaigns/opportunities in the platform, in which you participated, and examples of previous and current work product.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
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.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
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;
personal 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.
HelloConvo may also request payment account information (such as PayPal or a credit card) which is encrypted and provided to third parties for the purpose of processing payment(s). In addition, HelloConvo collects supplemental data from public sites, IP addresses, and connected social media channels, to create a more robust user profile and increase the odds that a marketer will locate your profile for content opportunities.
As a California resident agreeing to the Terms of Service and Privacy Notice when creating an account on our Site(s), you consent to the access and collection of data and content from the social media accounts you have connected, including followers, friend lists, photos, videos, or similar content published through those social media accounts. You have the option to change these choices made at registration, at any time, or request deletion of this personal information per this Notice and California law. However, the decision to disconnect a social media account will not remove content or data previously gathered.
California residents who are Marketers agreeing to creating an account on our Site(s), upon registration will be asked to provide an email address, establish a password, and provide payment account information. This data is required in order to make our services available to you.
How HelloConvo Uses Your Personal Information
HelloConvo uses collected personal information for its primary business purpose of providing advertising services, and all related purposes, including matching Influencers with Marketers for advertising and marketing opportunities.
HelloConvo may also use personal information as described to you when collecting your personal information or as otherwise set forth in the CCPA or to: communicate with you, provide you with Opportunities, to fulfill or meet the reason for which the information is provided, deliver support to enhance your user experience, improve our Sites, perform troubleshooting, testing, research, and analysis, respond to your inquiries, communicate news about HelloConvo or features and functionalities of the Platform, present you with surveys or commercial offers you may be interested in, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections, protect the rights, property, or safety of HelloConvo or its customers or others, or respond to law enforcement or legal requests as required by applicable law, court order, or governmental regulations. You may control your email preferences within your account in the Platform or contact us.
HelloConvo Does Not Sell Your Personal Information
HelloConvo does not sell personal information to third parties, and has not sold any personal information in the preceding twelve (12) months.
It should be noted that on some portions of the Sites, users can choose to have their personal information displayed. If users choose to have their personal information displayed on the Site(s), they will be given forewarning that the action they are about to take will make their personal information publicly available on the Site(s).
Sharing Your Personal Information
HelloConvo may disclose your personal information to a third party pursuant to a business purpose of providing advertising services, and all related purposes, including matching Influencers with Marketers for advertising and marketing opportunities. When HelloConvo discloses your personal information for a business purpose, we enter 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.
HelloConvo shares your personal information third party service providers, affiliates, 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category C: Protected classification characteristics under California or Federal law.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
II. California User Rights
Your 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.
Access to Specific Information and Data Portability Rights
You have the right to request that HelloConvo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once HelloConvo receives and confirms 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 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).
If we 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.
Deletion Request Rights
You have the right to request that HelloConvo delete any of your personal information that we collected from you and retained, 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. HelloConvo may also deidentify (anonymize) or aggregate data, at which point it shall no longer be deemed personal information subject to a deletion request.
HelloConvo may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
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.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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 (Cal. Penal Code § 1546 et. seq.).
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.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to HelloConvo by sending us an email to firstname.lastname@example.org or via regular mail to Data Protection Officer, 201 Marin Boulevard, Jersey City, New Jersey 07302, USA. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer 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.
HelloConvo 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.
Responding to Your Requests
HelloConvo endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional 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 that account. If not, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
HelloConvo does not charge a fee to process or respond to your verifiable consumer 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.
HelloConvo’s Non-Discrimination Policy
HelloConvo will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you services.
Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of services.
Suggest that you may receive a different price or rate for services or a different level or quality of services.
III. Changes to this Notice
HelloConvo reserves the right to amend or alter this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on our website and update the Notice’s effective date. Your continued use of the Sites following the posting of changes constitutes your acceptance of such changes.
IV. Contact Us
If you have any questions or concerns about this Notice, please feel free to contact us any time through the Sites or at Data Protection Officer, c/o HelloConvo LLC, 201 Marin Boulevard, Jersey City, New Jersey 07302, USA or email@example.com.