Brad’s Deals Privacy Notice for California Residents

Effective Date: 1/1/2020

Last Reviewed on: 1/1/2020

At Brad's Deals, we are committed to providing you the highest quality products and services and the highest level of integrity in dealing with our clients and partners. The Brad's Deals Privacy Policy explains how we collect, use and safeguard the personal information you provide to us at our website, our mobile apps, our Amazon Alexa Skills, and otherwise through our products and services (the “Site”). In keeping with our promise to continuously assess our policies and procedures, we are adding this supplemental privacy notice in light of the adoption of an important new law that applies to consumers residing in the state of California.

CCPA Privacy Notice

This Privacy Notice for California Residents (“CCPA Privacy Notice”) supplements the information contained in the Brad’s Deals Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). The information and procedures we outlined in our Privacy Policy continue to apply to all users residing outside of the state of California, and where they do not conflict with this CCPA Privacy Notice, the standard Brad’s Deals Privacy Policy remains in effect for California consumers as well. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Notice.

Information We Collect

On our Site, we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes
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 and debit card number (including expiration dates and/or card verification numbers), or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes
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). Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
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, web log files, IP addresses, 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. No
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. No
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

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

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

We 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.

We use cookies or similar tools to capture your individual e-mail address or other personal information about you, though data from cookies and similar tools do permit us to send focused online banner advertisements and related content to you. For more information, see section 2 of the Privacy Policy.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, 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 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. 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.

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

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

We disclose your personal information for a business purpose to the following categories of third parties:

Generally, disclosure of personal information includes hashed e-mail addresses and cookie activity, as set forth Section 2 of the Brad’s Deals Privacy Policy. “Hashing” is a form of anonymization that converts one piece of data to another. Accordingly, some of the personal information that we disclose to third parties may be sufficiently deidentified as to be excluded from the CCPA’s scope, as set forth in the definition of “personal information” provided in the Information We Collect section above.

In the preceding twelve (12) months, we have not disclosed the following categories of personal information for a business purpose:

Sales of Personal Information

In the preceding twelve (12) months, we have sold the following categories of personal information:

We sell your personal information to the following categories of third parties:

In the preceding twelve (12) months, we have

not sold personal information within the following categories:

We currently do not collect, disclose or sell telephone numbers, Social Security numbers, credit/debit card numbers, or other professional, physical, financial, medical or health formation. We have built in technology to our Site with third-party vendor Braintree for payment processing. We host code for Braintree’s technology on our site during our registration process to aid in providing services to you. In our registration process, you may be prompted to enter information related to credit or debit cards or other forms of payment. However, we do not see, receive, or store any such data; instead, Braintree sends us a token that contains no personal information that allows us to link your account to their technologies so that we can provide the highest quality service, data security and privacy.

Third-Party Privacy Policies

Brad’s Deals LLC has financial relationships with merchants on our Site, through which we may be compensated when you choose to apply for or purchase products or services via the links on our Site. This business practice does not constitute the sale of any personal information, but it could result in the disclosure of personal information to our merchants. Each merchant has its own privacy policies, and while we are not responsible for any third party’s privacy policies, we do encourage you to review any such policies.

Non-personal information

In general, we permit third-party companies to collect certain information when you visit our Site and services provided in connection with it, such as e-mail communications. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of greater interest to you on unaffiliated websites, apps, online service for advertising, analytics, attribution, reporting, and targeted e-mails based items viewed on a particular website. For more information, see the “Do We Disclose Information Outside Parties?” section of the Privacy Policy.

Your CCPA Rights and Choices

The CCPA provides California residents who are consumers of our services as set forth on our Site 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 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 data portability request (see the Exercising Access, Data Portability, and Deletion Rights section in this CCPA Privacy Notice), we will disclose to you:

Deletion Request Rights

You have the right to request that we 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.

Exercising 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 by either:

Only you, or someone legally authorized 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:

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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

Personal Information Sales Opt-Out and Opt-In Rights

As set forth in the Brad’s Deals Privacy Policy, (a) our services are for a general audience and are not directed at children under the age of 13; (b) users represent that they are at least 18 years old and understand that they must be at least 18 years old in order to create an account and purchase the goods or services advertised through our services. If we obtain actual knowledge that an account is associated with a registered user who is not at least 18 years old, we endeavor to delete personal information associated that account as soon as is commercially practicable.

However, in some instances, our knowledge of a user using our services who is not at least 18 years old may arise after such user has accessed and used our services, such that we may for a period unknowingly collect, store, or disclose personal information of individuals under 18 years old. Accordingly, we provide the following notice as required by the CCPA:

If you are a California consumer who is 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the California consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a California consumer less than 13 years of age. Consumers who opt in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you or your authorized representative may submit a request to us by visiting the following Internet Web page link:

California Residents: DO NOT SELL MY PERSONAL INFORMATION

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time. Users who are eligible to exercise the right to opt-in at any time. For either form of opt-in, you may do so by contacting us at:

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. We may require up to ninety (90) additional days to respond, if commercially reasonable. If we require more time, 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 or to contact information associated with it. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, requesting a written response will require you to provide us with a valid e-mail or postal address, which we will use solely to furnish our response to your request.

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, in our reasonable discretion.

We do 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. 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.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes within the preceding calendar year. In particular, this law provides that companies must inform California consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. Under this law, because we maintain a free and public privacy policy that allows users to opt out of information sharing, we are exempt from these requirements and instead utilize the procedures for disclosure and opt-out as set forth in this CCPA Privacy Notice.

California’s Online Privacy Protection Act (Cal. Bus. & Prof. C. §§22575-22579) (“CalOPPA”), requires website operators to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information of a consumer over time and across third party websites and apps, to the extent the operator engages in that collection. At this time, we do not respond to Do Not Track (DNT) signals. This law also requires website and app operators to disclose whether third parties may collect personally identifiable information about their users’ online activities over time and across different websites and apps when the users use the operator’s website or app. The nature of how third parties may collect or receive personally identifiable information is disclosed in this CCPA Privacy Notice as well as the standard Brad’s Deals Privacy Policy. To learn more about how Do Not Track signals work, please visit http://allaboutdnt.com/.

California residents may request to review changes to their personal information as collected by Brad’s Deals by contacting us as set forth in Exercising Access, Data Portability, and Deletion Rights section, above.

Changes to Our CCPA Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at our discretion and at any time. When we make changes to this CCPA Privacy Notice, we will post the updated notice on the Site and update the notice’s effective date. We review this CCPA Privacy Notice at least once per each 12-month period. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this CCPA Privacy Notice, the ways in which Brad’s Deals collects and uses your information described here and in the Brad’s Deals Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 877-809-1659

Website: www.bradsdeals.com/do-not-sell-my-personal-information

Email: privacy@bradsdeals.com

Postal Address:
Brad’s Deals LLC
Attn: Legal/California Privacy Rights
6115 Estate Smith Bay, Suite 315
St. Thomas, U.S. Virgin Islands 00802

Brad’s Deals Privacy Notice for Nevada Residents

Effective Date: 1/1/2020

At Brad’s Deals, we are committed to providing you the highest quality products and services and the highest level of integrity in dealing with our clients and partners. The Brad’s Deals Privacy Policy explains how we collect, use and safeguard the personal information you provide to us at our website, our mobile apps, our Amazon Alexa Skills, and otherwise through our products and services (the “Site”). In keeping with our promise to continuously assess our policies and procedures, we are adding this supplemental privacy notice in light of the adoption of an important new law that applies to consumers residing in the state of Nevada.

This Privacy Notice for Nevada Residents (“Nevada Privacy Notice”) supplements the information contained in the Brad’s Deals Privacy Policy and applies solely to all visitors, users, and others who reside in the State of Nevada (“consumers” or “you”). The information and procedures we outlined in our Privacy Policy continue to apply to all users residing outside of the state of Nevada, and where they do not conflict with this Nevada Privacy Notice, the standard Brad’s Deals Privacy Policy remains in effect for Nevada consumers as well. We adopt this notice to comply with Nevada SB 220, which amends Nevada’s Online Privacy Law, NRS 603A (“SB 220”). Any terms defined in SB 220 have the same meaning when used in this Nevada Privacy Notice.

Our Requirements under SB 220

SB 220 requires us to establish a designated request address through which a Nevada consumer may submit a verified request directing us not to make any sale of Covered Information collected about the consumer. If you make such a request and we are able to verify it, SB 220 prohibits us from making any sale of any Covered Information collected about you.

In light of our ongoing commitment to your privacy as part of providing you the highest quality products and services and the highest level of integrity in dealing with our clients and partners, and in order to carry out our obligations to Nevada consumers under SB 220, we are making the disclosures and setting the policies and procedures outlined below.

Covered Information

For purposes of SB 220, “Covered Information” includes the following pieces of information about a consumer that we may collect through the Site or online service and that we may maintain in an accessible form: (1) a natural person’s first and last name; (2) a physical address which includes the name of a street and the name of a city or town; (3) an e-mail address; (4) a telephone number; (5) a social security number; (6) an identifier that allows a specific person to be contacted; or (7) any other information concerning a person collected from the person through the Site and maintained in combination with an identifier in a form that makes the information personally identifiable.

Covered Information That We Collect

We may collect the following Covered Information:

We currently do not collect other categories of Covered Information under SB 220, including postal mailing addresses, telephone numbers, other additional contact information, social security numbers, driver’s license numbers, personal identification card numbers, medical/health/insurance information, or bank account or other financial information.

Please see the Brad’s Deals Privacy Policy for complete disclosure of the categories of Covered Information that we may collect and for more information about technologies we use to collect information and how we safeguard it. For more information about how we use your Covered Information please see Section 2 of the Privacy Policy, entitled “Site Use Information.”

Covered Information That We Disclose

We currently disclose some Covered Information of Nevada consumers to third parties. Such Covered Information may include your first and last name, your e-mail address, your IP address, and your age and gender.

Covered Information That We Sell

For purposes of SB 220, a “Sale” is the exchange of Covered Information for monetary consideration by us to a person for the person to license or sell the covered information to additional persons. A Sale does not include our disclosure of Covered Information to any of the following:

(a) A person who processes the Covered Information on our behalf;

(b) A person with whom you have a direct relationship for the purposes of providing a product or service you requested;

(c) A person for purposes which are consistent with your reasonable expectations considering the context in which you provided us the Covered Information;

(d) Any of our affiliates, which under Nevada law means any company that controls, is controlled by, or is under common control with us; or

(e) A person as an asset that is part of a merger, acquisition, bankruptcy or other transaction in which the person assumes control of all or part of our assets.

We currently engage in the Sale of some Covered Information of Nevada consumers to third parties. Such Covered Information includes your first and last name, your e-mail address, and your IP address. Third parties to whom we sell may include service providers, including e-mail marketing, sponsored content, and data analysis companies like LiveIntent, ALC, Cross Pixel, Circulate/LiveRamp, and Paved.

Your Opt-Out Rights

You may make a request to opt out of the Sale of any Covered Information (an “Opt-Out Request”). We may verify your Opt-Out Request according to the Verification section below. If we are able to verify your Opt-Out Request, we will no longer make any Sale of your Covered Information. You are entitled to make an Opt-Out Request regardless of whether we engage in the Sale of any Covered Information.

Verification

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We reserve the right to reasonably verify the authenticity of the request, including verifying your identity as the consumer making the request.

The verifiable consumer request must:

We cannot respond to your request or provide you with Covered Information if we cannot verify your identity or authority to make the request and confirm the Covered Information relates to you. We will only use Covered Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. The response we provide will explain the reasons we cannot comply with a request, if applicable.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within sixty (60) days of its receipt. However, we may extend this response period by as many as thirty (30) additional days if we determine it reasonably necessary. If we extend the response period, we will notify you of the extension.

If you have an account with us, we will deliver our written response to that account or to contact information associated with it. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If you do not have an account with us, requesting a written response will require you to provide us with a valid e-mail or postal address, which we will use solely to furnish our response to your request.

We do 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.

Changes to this Policy

We reserve the right to amend this Nevada Privacy Notice at our discretion and at any time. When we make changes to this Nevada Privacy Notice, we will post the updated notice on the Site and update the notice’s effective date. We review this Nevada Privacy Notice regularly. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Exercising Opt-Out Request

To exercise the Opt-Out Request rights described above, please submit a verifiable consumer request to us by postal mail at the following address:

If you have any questions or comments about this Nevada Privacy Notice, the ways in which Brad’s Deals collects and uses your information described here and in the Brad’s Deals Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under Nevada law, please do not hesitate to contact us by writing to the address above or via our Site at www.bradsdeals.com/contact-us.

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