CCPA Privacy Policy for California Residents

Effective Date: January 2025  

Last Updated on: January 2025  

This Privacy Policy for California Residents supplements the information contained  in Creation Rights' [HYPERLINKED URL TO GENERAL PRIVACY POLICY] and applies  solely to all visitors, users, and others who reside in the State of California ("consumers"  or "you"). We adopt this notice to comply with the California Consumer Privacy Act of  2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in  this Policy.  

This Policy does not apply to workforce-related personal information collected from  California-based employees, job applicants, contractors, or similar individuals.  

Where noted in this Policy, the CCPA temporarily exempts personal information  reflecting a written or verbal business-to-business communication ("B2B personal  information") from some its requirements.  

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.  
• Deidentified or aggregated consumer information.  
• Information excluded from the CCPA's scope, like:
  1. 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), clinical trial data, or other qualifying research  data;  
  2. 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  consumers within the last twelve (12) months: 

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 Website.  

Use of Personal Information  

We may use, sell, 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, if you  share your name and contact information to request a price quote or ask a  question about our products or services, we will use that personal information to  respond to your inquiry. If you provide your personal information to purchase a  product or service, we will use that information to process your payment and  facilitate delivery. We may also save your information to facilitate new product  orders or process returns.  
• To provide, support, personalize, and develop our Website, products, and  services. 
• To create, maintain, customize, and secure your account with us. 
• To process your requests, purchases, transactions, and payments and prevent  transactional fraud.  
• 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 Website experience and to deliver content and product and  service offerings relevant to your interests, including targeted offers and ads  through our Website, 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 Website, products and  services, databases and other technology assets, and business.  
• For testing, research, analysis, and product development, including to develop  and improve our Website, products, 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 Website 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 share your personal information by disclosing it to a third party for a business  purpose. We only make these business purpose disclosures under written contracts that  describe the purposes, require the recipient to keep the personal information  confidential, and prohibit using the disclosed information for any purpose except  performing the contract. In the preceding twelve (12) months, the Company has not  disclosed personal information for a business purpose to the categories of third parties  indicated in the chart below.  

We may also share your personal information by selling it to third parties, subject to your  right to opt-out of those sales. Our personal information sales do not include information  about individuals we know are under age 16. In the preceding twelve (12) months,  Company has not sold personal information to the categories of third parties indicated in  the chart below. For more on your personal information sale rights, see Personal  Information Sales Opt-Out and Opt-In 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.  

Right to Know and Data Portability  

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 (the "right to  know"). Once we receive your request and confirm your identity (see Exercising Your  Rights to Know or Delete), 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.
• If we sold or disclosed your personal information for a business purpose, two  separate lists disclosing:
  1. sales, identifying the personal information categories that each category of  recipient purchased; and  
  2. disclosures for a business purpose, identifying the personal information  categories that each category of recipient obtained.  
• The specific pieces of personal information we collected about you (also called a  data portability request).  

We do not provide a right to know or data portability disclosure for B2B personal  information.  

Right to Delete  

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 (the "right to delete").  Once we receive your request and confirm your identity (see Exercising Your Rights to  Know or Delete), we will review your request to see if an exception allowing us to retain  the information 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.  

We will delete or deidentify personal information not subject to one of these exceptions  from our records and will direct our service providers to take similar action.  

We do not provide these deletion rights for B2B personal information.  Exercising Your Rights to Know or Delete  

To exercise your rights to know or delete described above, please submit a request by  either:  

• Calling us at +1 212-624-2518.  
• Emailing us at creationrights@gmail.com.  

Only you, or someone legally authorized to act on your behalf, may make a request to  know or delete related to your personal information.  

You may also make a request to know or delete on behalf of your child by emailing us at  creationrights@gmail.com.  

You may only submit a request to know twice within a 12-month period. Your request to  know or delete 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:
  1. Proof of ID.  
  2. Proof of Authority to Act.  
  3. Proof of Guardianship.  
• 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.  

You do not need to create an account with us to submit a request to know or delete.  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 the request to verify the requestor's  identity or authority to make it.  

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

Response Timing and Format  

We will confirm receipt of your request within ten (10) business days. If you do not  receive confirmation within the 10-day timeframe, please contact  

creationrights@gmail.com.  

We endeavor to substantively respond to a verifiable consumer request within forty-five  (45) days of its receipt. If we require more time (up to another 45 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 our receipt of  your request. 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  

If you are age 16 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 old. 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:  

"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 by:  

E-mail: creationrights@gmail.com 

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.  

Non-Discrimination  

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.  

Changes to Our Privacy Policy  

We reserve the right to amend this privacy policy at our discretion and at any time.  When we make changes to this privacy policy, we will post the updated notice on the  Website and update the notice's effective date. Your continued use of our Website  following the posting of changes constitutes your acceptance of such changes.  

Contact Information  

If you have any questions or comments about this notice, the ways in which Creation  Rights collects and uses your information described here and in the 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:  

If you need to access this Policy in an alternative format due to having a disability,  please contact creationrights@gmail.com and +1 212-624-2518.