Last Updated: July 29, 2021
Categories of Personal Information Drifty Collects
We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a Consumer or device.
Personal Information does not include (i) publicly available information that is lawfully made available to the general public by way of federal, state, or local government records; (ii) de-identified or aggregated consumer information; and (iii) information excluded from the CCPA’s scope, like: (a) 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, and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We have collected the following categories of Personal Information from Consumers within the last twelve (12) months:
Category Personal Information
(corresponds to categories listed in CCPA §1798.140(o)(1))
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.
B. Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
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, or any other financial information, medical information, or health insurance information.
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 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
Current or past job history or performance evaluations.
J. Non-public education information
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.
In addition to the information you may provide to us as set forth below, if you apply for a job on our website or become an employee, we may also collect:
A. Identifiers: your account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal Information(as listed in the CCPA): 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, or any other financial information, or health insurance information.
G. Geolocation Data: physical location when you apply for a job or interact with our website.
I. Professional or employment-related information: current or past job history.
J. Non-public education information: 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.
K. Inferences drawn from other personal information: profiles reflecting a person’s preferences and behavior, for example, as part of management training.
Sources of Personal Information
Drifty obtains the categories of Personal Information listed in the Table above from the following categories of sources:
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
Drifty 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
Drifty 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:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Drifty has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records Personal Information categories.
Category F: Internet or network activity.
Category I: Professional or employment-related information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
Sales of Personal Information
For purposes of the CCPA, Drifty has not sold Personal Information in the preceding twelve (12) months.
Your Rights and Options
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. Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA:
Access to Specific Information and Data Portability Rights
You have the right to request that Drifty 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:
Deletion Request Rights
You have the right to request that Drifty 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:
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 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:
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.
We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
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
We do not sell personal information to third parties.
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 Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com, or write us at: Drifty Co. (d/b/a Ionic), 121 S. Pinckney St. Suite 300 Madison, WI 53703; Attn: Privacy.
Changes to Our Privacy Notice
Drifty reserves 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 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.
Drifty Co. (d/b/a Ionic)
121 S. Pinckney St.
Madison, WI 53703