Under the California Consumer Privacy Act (CCPA), California residents have certain rights related to their personal information collected by and on behalf of a business subject to the law. Students also have certain privacy rights under U.S. Family Educational Rights and Privacy Act (FERPA).
For purposes of this Supplemental Privacy Statement for California Residents, Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or their household.
FERPA Privacy Rights. FERPA provides students with privacy rights and protection for educational personally identifiable information collected and processed on behalf of educational institutions receiving government funding from the U.S. Department of Education. FERPA provides students with rights to obtain from these educational institutions access to their educational records, as well as correction and amendment of their educational records, even though the CCPA does not apply to non-profit and public educational institutions.
CCPA Right to Know. California residents may request a business to disclose the following information about the business’ collection and use of their personal information over the past twelve (12) months, provided that such requests are made no more than twice within a twelve (12) month period:
- The categories of personal information collected;
- The categories of sources for the personal information collected;
- The business or commercial purpose for collecting, and, if applicable, selling, personal information;
- The specific pieces of personal information collected;
- If the personal information has been disclosed, the categories of personal information disclosed and the categories of third parties receiving the personal information;
- If the personal information has been sold, the categories of personal information sold and the categories of third parties to whom the personal information was sold.
CCPA Right to Deletion. California residents may request a business to delete the personal information that the business collected and has been retained by the business or its service providers. This right is limited, and the business may deny a deletion request if it is necessary for the business or a service provider to maintain the personal information in order to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the individual, or reasonably anticipated within the context of a business’ ongoing business relationship with the individual, or otherwise perform a contract between the business and the individual.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech ensure the right of another individual to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, where the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the individual has provided informed consent;
- Enable solely internal uses that are reasonably aligned with the expectations of the individual based on the individual’s relationship with the business;
- Comply with a legal obligation;
- Otherwise use the individual’s personal information, internally, in a lawful manner that is compatible with the purpose for which the individual provided the information.
CCPA Right to No Sale of Personal Information. A California resident has the right to opt-out of the sale of their Personal Information by a business subject to the CCPA. In addition, a business subject to the CCPA must have affirmative authorization in order to sell the Personal Information of a California resident who it knows is under the age of 16. As explained above, we do not sell Personal Information, except to the extent that third party advertising cookies are ultimately determined to be a “sale” under the California Consumer Privacy Act. Additional information is available on our Do Not Sell My Personal Information page, including information about how to manage or block these cookies. We do not engage in targeted advertising to individuals who we know are under the age of 16. We also do not use Personal Information that we collect as a K-12 school service provider for the purpose of directed or targeted advertising.
CCPA Right to Non-Discrimination. A business subject to the CCPA may not discriminate against a California resident for exercising any of their CCPA privacy rights.