Wana Family Network is the Public Benefit Corporation home of Komae and Sitster. Whether you’re a Komae family or a Sitster family, this Privacy Supplement is for you. (And you can learn more about Wana Family Network here.)
Effective Date: January 1, 2020
INFORMATION WE COLLECT
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: 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, or 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.
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
Categories of Personal Information:
- A. Identifiers (such as name, address, email address)
- B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (such as name, address, telephone number)
- C. Protected classification characteristics under California or federal law (such as age (40 years or older)
- F. Internet or other similar network activity (such as your interaction with the Site and Services)
- K. Inferences drawn from other personal information (such as a profile reflecting a person’s preferences, behavior, and attitudes).
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase
- Indirectly from you. For example, from observing your actions on our Site and Services
- Internet cookies
USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, to provide use and access of the Site and Services to you
- To provide, support, personalize, and develop our Services and Site
- To create, maintain, customize, and secure your account with us
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers through our Site, third-party sites, and via email or text message (with your consent, where required by law)
- To help maintain the safety, security, and integrity of our Site and Services, databases and other technology assets, and business
- For testing, research, analysis, and product development, including to develop and improve our Site and Services
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- As described to you when collecting your personal information or as otherwise set forth in the CCPA
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
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.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose. 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.
We share your personal information with the following categories of third parties:
- Service providers
- Data aggregators
- Affiliates and partners
- Internet cookie data recipients, like Google Analytics.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers
- Category B: California Customer Records personal information categories
- Category C: Protected classification characteristics under California or federal law
- Category F: Internet or other similar network activity
- Category K: Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers
- Data aggregators
- Affiliates and partners
- Internet cookie data recipients, like Google Analytics.
Sales of Personal Information
In the preceding twelve (12) months, the Company has not sold personal information.
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 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 sold or 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 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:
- 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 your use of our services, 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 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:
- Emailing us at firstname.lastname@example.org
- Visiting here
- Through your password-protected account with us.
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. To designate an authorized agent, please provide us with written authorization for the agent to act on your behalf. You will still need to verify your identity directly with us.
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, which may include you name, address, email address, and other identifiers
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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 you do not have an account with us, 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. 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.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to opt out of our sale(s) of your personal information. Please be advised that we do not currently sell personal information. This opt-out, however, would apply to the extent we began to engage in sales of personal information governed by the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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.
CALIFORNIA SHINE THE LIGHT
We do not share personal information with third parties for their direct marketing purposes.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice [here] and update the notice’s effective date. Your continued use of our Site and Services following the posting of changes constitutes your acceptance of such changes.
Wana Family Network PBC
Attn: Erin Beck, CEO
3371 Glendale Blvd., #124
Los Angeles, CA 90039