PRIVACY POLICY
Last Updated & Effective Date: October 22, 2020

This Privacy Policy explains how information about you is collected, used and disclosed by Netizen, LLC (“Netizen”). Netizen operates a network platform through which web properties can display certain third party content such as articles, videos, blog posts, and advertisements on their sites (the “Services”).  This Privacy Policy describes how Netizen collects, uses, and discloses information when you visit this website (“the Site”) and websites and mobile applications that integrate the Services.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy.  We encourage you to check back regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information We Collect Automatically Through the Services

In order to help provide recommendations and promoted content that is relevant to your interests, we automatically collect certain information when you access websites and mobile applications that incorporate the Services. This information reflects information about the websites you visit, the mobile applications you use, and how you interact with our Services. The following describe the categories of personal information we collect about Consumers, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share such personal information, information about the specific pieces of personal information we collect about Consumers, and any of which we have collected in the preceding twelve (12) months.

Browser and Device Information: We collect information about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier, and identifiers assigned to your browser or device.

Usage Data: We collect information about the websites and mobile applications you visit that integrate our Services and about the websites that you visit immediately prior to visiting a website that integrates our Services, including the date and time your browser or device accesses such websites and the specific pages accessed.

Click Data: We collect information about the content and ads that you click on within the Services.

Information You Provide

In certain instances, you may be able to customize your experience by creating a user account or by logging in through one or more social media services. If you log in or otherwise link an existing social media account, we will have access to certain information from that service, such as your name, profile information, likes, shares, posts, etc., in accordance with the authorization procedures determined by the social media service you use to login.

You also may be able to customize your Netizen experience by registering as a user directly with the Netizen and selecting topics of interest to customize your experience. If you do this, we will have access to the information you provide in doing so, including your name, contact information, and any preferences or interests you select.

Information We Collect from Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services.  For example, we may collect information about you from third parties, including our business partners, other advertising companies, and publicly available sources.

Cookies and Other Tracking Technologies We Use to Collect Information

We use various technologies to collect information, including cookies, web beacons, web storage, unique device identifiers, and similar technologies.  Cookies are small data files stored on your hard drive or in device memory that help us to tailor recommendations and promoted content to your preferences over time.  For example, we may use your web browsing information to show you specific recommendations and sponsored recommendations that we think will be of particular interest to you.  We may also collect information using web beacons (also known as “tracking pixels”).  Web beacons are electronic images that may be used in our Services and help perform a variety of functions, including delivering cookies, counting visits, and understanding usage.  For more information about cookies, and how to disable them, please see “Your Choices” below.

USE OF INFORMATION

We use the information we collect to determine what content is most relevant to you, to disseminate recommendations and promoted content to you, and to understand, measure, and report on how users interact with the Services.  We also use the information we collect from the Service to maintain and constantly improve upon the Services.

SHARING OF INFORMATION

We may share the information we collect as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property or safety of Netizen or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Netizen and any current or future parent, subsidiary and/or affiliated company; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.  For example, we may share de-identified information with advertisers that partner with us to help them understand how well their advertisements performed.

YOUR CHOICES

Opting out of Personalized Content

You may opt out of receiving personalized content and advertisements from Netizen by clicking the “Opt Out” button at the top of this page.  When you opt out, we will set a cookie on your browser that tells us not to personalize recommendations or promoted content on that browser or to record information about the sites you are visiting.  If you use multiple devices and/or multiple browsers, you need to opt out on each device and browser you use, even if you login to Netizen using a social media account.

Please note that even after you have opted out, you will still see Netizen recommendations and promoted content, but these recommendations and promoted content will not be personalized based on the sites you visit.

Note that if you clear your cookies, you will need to opt out again.

For information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes by companies that participate in the Digital Adverting Alliance, please visit www.aboutads.info/choices. If you are in the EU, you may opt out at the European Digital Advertising Alliance, http://www.youronlinechoices.eu/.  

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of some websites.

INFORMATION COLLECTED ON OUR WEBSITE

Advertisers and publishers may provide contact information through our Site to find out more about Netizen, be contacted by a Netizen representative, or to start working with Netizen. Netizen (and its agents and service providers) may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research. We will also use the information we collect from advertisers and publishers for invoicing and billing purposes. We will not rent or sell this information to other companies. You may opt out of receiving promotional emails from Netizen by following the instructions in those emails or by emailing us at privacy@Netizen.com.  If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations. 

Netizen may also work with third parties that collect data on our Site and on other websites to serve you targeted ads.  You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program by visiting about http://optout.aboutads.info/. If you are in the EU, you may opt out at the European Digital Advertising Alliance, http://www.youronlinechoices.eu/.

DATA RETENTION

We store the information we collect for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

DATA TRANSFERS AND PRIVACY SHIELD

Netizen is based in the U.S.  As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.  We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. 

When we transfer personal data from the European Union or Switzerland to the United States, we comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States, respectively. Netizen has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we are committed to resolving complaints about our processing of your personal data. EU and Swiss individuals with inquiries or complaints regarding our compliance with the Privacy Shield program should first contact us at privacy@Netizen.com  We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. Netizen is subject to the investigatory and enforcement powers of the Federal Trade Commission.

If we share personal data transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

HOW WE PROTECT THE INFORMATION WE COLLECT

We take reasonable measures to help protect the information we collect from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.  However, no transmission over the internet or electronic storage can be completely secure, so we cannot guarantee the absolute security of any data.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested). 
  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to provide content and advertisements that may be of interest to you, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
  • There is another applicable lawful basis under which we are permitted to process your personal data. 

Data Subject Requests 

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict, certain processing.  If you would like to exercise any of these rights, please contact us at privacy@Netizen.com  

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.  For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

RESIDENTS OF THE STATE OF CALIFORNIA

 

For Residents of the State of California, the following provisions address the foundational principles of the California Consumer Privacy Act of 2018.

 

  • DATA PROTECTION PRINCIPLES

 

The COMPANY is committed to processing data in accordance with its responsibilities under the CCPA, and in particular with regard to the principles articulated therein which affirm a right to privacy, provide California consumers should be able to exercise control over their personal information, and provide that there are safeguards against misuse of their personal information. 

 

Those principles require that where this organization collects personal information about a consumer who is a California resident (“Consumer” or hereinafter “consumer”) the Consumer has a right to request disclosure of:

  1. the categories and specific pieces of personal information we collect;
  2. the categories of sources from which that information is collected;
  3. the business purposes for collecting or selling the information;
  4. the categories of third-parties with which the information is shared;
  5. disclosures about the information, and
  6. the purposes for which the information is used.

 

Those principles also require upon verified request:

  1. the deletion of personal information;
  2. disclosure of the categories of information collected that we sell or disclose; and
  3. the disclosure of the identity of third-parties to whom the information was sold or disclosed;

 

And, among other rights, 

  1. authorize the Consumer to opt out of the sale of personal information; and
  2. prohibit discrimination against the Consumer for exercising privacy rights.

 

While we operate primarily if not exclusively as a Service Provider under the CCPA, we are committed to supporting those rights and do so with the following policy provisions, as applicable.

 

  • GENERAL PROVISIONS
  1. This policy applies to all California resident consumer personal information (“Consumer Data”) processed or controlled by the COMPANY. 

 

  1. Personal information (“Consumer Data”) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  It includes identifiers such as 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 anything similar. “Personal information” does not include publicly available information. “Personal information” does not include consumer information that is deidentified or aggregate consumer information.
  2. This policy shall be reviewed at least annually. 
  3. The COMPANY shall comply with an order of the California Attorney General.
  4. The COMPANY shall seek to cure violations of the CCPA within 30 days of written notice of alleged noncompliance by a consumer. 
  5. To ensure its processing of data is lawful, fair and transparent, the COMPANY shall maintain a Register of Systems which shall include a list of systems containing personal information of California consumers, service providers and third-parties (as that term is defined in the CCPA Regulations) with which it does business.
  6. The Register of Systems shall be reviewed at least annually. 

 

  • LAWFUL, FAIR AND TRANSPARENT PROCESSING 
  1. Where the COMPANY collects personal information about a Consumer, upon receipt of a verifiable Consumer request, the COMPANY shall disclose to that consumer the categories and specific pieces of personal information the business has collected and shall disclose and deliver promptly and free of charge.  See 5(a) and (b) below for the information to be provided.
  2. Where such information is disclosed and delivered, it shall, be delivered by mail or electronically, and, if delivered electronically, it shall be provided in a portable form and, to the extent technically feasible, delivered in a readily useable format that allows the consumer to transmit this information to another entity without hindrance.
  3. Where the COMPANY collects a Consumer’s personal information, it shall, at or before the point of collection, inform consumers as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. The COMPANY shall not collect additional categories of personal information or use personal information collected for additional purposes without providing the Consumer with notice.

 

  • RIGHT TO BE FORGOTTEN 
  1. Where the COMPANY collects personal information about a Consumer, it shall, upon verified request, delete any personal information about the Consumer which the COMPANY has collected from the Consumer from its records and direct any service providers to delete the Consumer’s personal information from their records.
  2. Where the COMPANY collects personal information about a Consumer, it shall disclose to the Consumer the Consumer’s rights to request the deletion of the Consumer’s personal information.
  3. This right to be forgotten shall not prevent the COMPANY from using the Consumer’s personal information to: 
  1. complete the transaction for which it was collected,
  2. detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
  3. debug to identify and repair errors that impair existing intended functionality,
  4. comply with the California Penal Code,
  5. engage in public or peer-reviewed scientific, historical, or statistical research in the public interest,
  6. enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business, or
  7. comply with a legal obligation or otherwise use the information in a lawful manner compatible with the context in which the information was given.

 

  • RIGHT TO BE INFORMED

 

WHERE THE COMPANY COLLECTS DATA

  1. Where the COMPANY receives a verified request under Section 3(a) above, the COMPANY shall provide to that Consumer: (1) the categories of personal information it has collected about that Consumer, (2) the categories of sources from which the personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information and (5) the specific pieces of personal information it has collected about that Consumer. 
  2. In so providing, the COMPANY shall identify by category or categories the personal information collected about the consumer in the preceding 12 months by reference to the above enumerated category or categories that most closely describes the personal information collected. 
  3. Where the COMPANY collects Consumer Data, the COMPANY shall disclose the following information concerning its practices over the past 12 months in its online privacy policy or policies and in any California-specific description of consumers’ privacy rights (or if the COMPANY does not maintain those policies, on its Internet Web site) and update that information at least once every 12 months: (1) the categories of personal information it has collected about Consumers, (2) the categories of sources from which the personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information and (5) the specific pieces of personal information it collects about Consumers. 
  4. In so disclosing, the COMPANY shall provide a description of consumers’ privacy rights, updated at least every 12 months, and list the categories of personal information it has collected about consumers in the preceding 12 months by reference to the enumerated category or categories that most closely describe the personal information collected. 

 

WHERE THE COMPANY SELLS OR DISCLOSES PERSONAL DATA

  1. Where the COMPANY sells personal information about a consumer, or discloses it for a business purpose, and receives a verifiable request from a Consumer, the COMPANY shall provide to that consumer: (1) the categories of personal information it has collected about that consumer, (2) the categories of personal information that the business sold about the consumer, (3) the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold and (4) the categories of personal information that the business disclosed about the consumer for a business purpose. 
  2. In so disclosing, the COMPANY shall (a) identify the consumer and associate the information provided by the Consumer in the verifiable request to any personal information previously collected by the business about the Consumer, (b) identify by category or categories the personal information of the consumer that the business sold in the preceding 12 months by reference to the above enumerated category that most closely describes the personal information, and (c) provide the categories of third parties to whom the Consumer’s personal information was sold in the preceding 12 months by reference to the enumerated category that most closely describes the personal information sold.
  3. In so disclosing, the COMPANY shall (a) identify the consumer and associate the information provided by the Consumer in the verifiable request to any personal information previously collected by the business about the Consumer, (b) identify by category or categories the personal information of the consumer that the business disclosed for a business purpose in the preceding 12 months by reference to the enumerated category or categories that most closely describes the personal information, and (c) provide the categories of third parties to whom the consumer’s personal information was disclosed for a business purpose in the preceding 12 months by reference to the enumerated category or categories that most closely describes the personal information disclosed in a list that is separate from a list generated for the purposes of identifying the information sold. 
  4. Where the COMPANY sells personal information about consumers, or disclose it for a business purpose, the COMPANY shall disclose the following information concerning its practices over the past 12 months in its online privacy policy or policies (if the COMPANY has an online privacy policy or policies) and in any California-specific description of consumers’ privacy rights (or if the COMPANY does not maintain those policies, on its Internet Web site) and update that information at least once every 12 months: (1) the category or categories of consumers’ personal information it has sold, or if the business has not sold consumers’ personal information, disclose that fact and (2) the category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, disclose that fact.
  5. In so disclosing, the COMPANY shall provide a description of consumers’ privacy rights, updated at least every 12 months, and shall identify by category or categories the personal information sold or disclosed about consumers in the preceding 12 months by reference to the aforementioned enumerated category or categories that most closely describes the personal information collected.
  6. In so disclosing, the COMPANY shall separately list the category or categories sold and the category or categories disclosed.

 

  • RIGHT TO OPT-OUT
  1. The COMPANY may not sell Consumer personal information unless the Consumer has been given the right, at any time, to opt-out.
  2. The COMPANY shall not sell Consumer Data that has been sold to it by another business unless the Consumer has received explicit notice and given the opportunity not to sell that consumer’s personal information (known as the right to opt-out).
  3. The COMPANY may not sell Consumer personal information unless the Consumer has been provided notice that this information may be sold and that consumers have the right to opt out of the sale of their personal information.
  4. Such notice shall be in a form that is reasonably accessible to consumers and: (1) provide a clear and conspicuous link on the COMPANY’s Internet homepage, titled “Do Not Sell My Personal Information,” to an Internet Web page that enables a consumer, or a person authorized by the consumer, to opt out of the sale of the consumer’s personal information, and (2) include a description of a consumer’s rights , along with a separate link to the “Do Not Sell My Personal Information” Internet Web page in: (A)  online privacy policy or policies if any, (B) any California-specific description of consumers’ privacy rights. 
  5. The COMPANY, if it sells consumer’s personal information, shall:
    1. ensure that all individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance are informed of all requirements and how to direct consumers to exercise their rights, 
    2. for consumers who exercise their right to opt out of the sale of their personal information, refrain from selling personal information collected by the business about the consumer, 
    3. for a consumer who has opted out of the sale of the consumer’s personal information, respect the consumer’s decision to opt out for at least 12 months before requesting that the consumer authorize the sale of the consumer’s personal information, and 
    4. use any personal information collected from the consumer’s opt-out request solely for the purposes of complying with the opt-out request.
  6. The COMPANY shall allow a consumer to authorize another person solely to opt-out of the sale of the consumer’s personal information on the consumer’s behalf.
  7. The COMPANY shall, once it has received direction from a consumer not to sell the consumer’s personal information or, in the case of a minor consumer’s personal information has not received consent to sell the minor consumer’s personal information, stop selling the consumer’s personal information, unless the consumer subsequently provides express authorization for the sale of the consumer’s personal information.
  8. The COMPANY shall not sell personal information of consumers where it has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information.

 

  • NO DISCRIMINATION 
  1. The COMPANY shall not discriminate against a Consumer for exercising its rights under California privacy law (such as denying services or charging a different price greater than the value of consumer’s data).
  2. Should the COMPANY provide financial incentives to consumers as compensation for the collection of personal information, they shall be fair and reasonable, and the COMPANY will require the consumer opt-in their consent in advance in a manner which clearly describes the material terms of the financial incentive program, and which opt-in may be revoked by the consumer at any time.
  3. The COMPANY shall provide a description of a consumer’s rights to no discrimination for exercising its rights under California privacy law in its online privacy policy or policies if the organization has an online privacy policy and in any California specific description of consumers’ privacy rights, or if it does not maintain those policies, on its Internet Web site, and update that information at least once every 12 months.

 

  • RIGHT TO NOTICE AND INFORMATION
  1. The COMPANY shall, for the purpose of receiving requests for information under the California Consumer Privacy law, make available for consumers at a minimum, two designated methods for submitting requests, including a toll-free telephone number, and if the COMPANY maintains an Internet Web site, a Web site address. Where the COMPANY operates exclusively online, it may, instead, provide an email address only.
  2. Where such a request is received, the COMPANY shall disclose and deliver the required information to a consumer free of charge within 45 days of receiving a verifiable request from the consumer (extended only once by an additional 45 days when reasonably necessary, provided the consumer is provided notice of the extension within the first 45-day period).
  3. The information is to be delivered through the Consumer’s account with us, if the consumer maintains an account with us, or by mail or electronically at the Consumer’s option if the Consumer does not maintain an account, in a readily useable format that allows the Consumer to transmit this information from one entity to another entity without hindrance. 
  4. The COMPANY’s online privacy policy or policies or any California-specific description of consumers’ privacy rights, (or by mail if the COMPANY does not maintain such policies on its Internet Web site) shall provide a description of a consumer’s rights under California privacy law and one or more designated methods for submitting requests (and shall be updated at least every 12 months).
  5. All individuals responsible for handling Consumer inquiries about the COMPANY’s privacy practices or compliance with California privacy laws are to be informed of all requirements concerning Consumers rights to request information concerning personal information collected, sold or disclosed, Consumers’ right not to be discriminated against and how to direct Consumers to exercise their rights.
  6. Any personal information collected from a Customer in connection with the COMPANY’s verification of a Customer’s request is to be used solely for the purposes of verification. 

 

  • RIGHT TO ACCESS

 

  1. Where access to customer personal data is provided to a vendor or service provider the COMPANY shall do so by written contract that: (1) specifies the business purpose for giving the data, (2) prohibits the retention, use or disclosure of that data on your behalf for any other purpose, (3) prohibits the retention, use or disclosure of that data for other commercial purposes, (4) prohibits the retention, use or disclosure of that information outside of the direct business relationship of the parties, (5) prohibits the sale of that data, and (6) requires compliance with California Privacy Laws as to that data including its restrictions on use, disclosure and retention. 

 

  1. Where access to customer personal data is provided to a vendor or service provider the COMPANY shall obtain a certification from the person receiving the data that they understand and will comply with the written contract that: (1) specifies the business purpose for giving the data, (2) prohibits the retention, use or disclosure of that data on your behalf for any other purpose, (3) prohibits the retention, use or disclosure of that data for other commercial purposes, (4) prohibits the retention, use or disclosure of that information outside of the direct business relationship of the parties, (5) prohibits the sale of that data, and (6) requires compliance with California Privacy Laws as to that data including its restrictions on use, disclosure and retention.

 

  • REASONABLE SECURITY AND BREACH NOTIFICATION

 

  1. The COMPANY shall implement and maintain reasonable security practices and procedures, appropriate to the nature of the information, to protect an individual’s first name or first initial and last name in combination with any one or more of the following data elements, when either the name or the data elements are not encrypted or redacted: (1) social security number, (2) Driver’s license number, California identification card number, tax identification number, passport number, military identification number, or other unique identification number issued on a government document commonly used to verify the identity of a specific individual, (3) account number or credit or debit card number, in combination with any required security code, access code, or password that would permit access to an individual’s financial account, (4) medical information, (5) health insurance information, and (6) unique biometric data generated from measurements or technical analysis of human body characteristics, such as a fingerprint, retina, or iris image, used to authenticate a specific individual – not including a physical or digital photograph, unless used or stored for facial recognition purposes.

 

  1. The COMPANY shall implement and maintain reasonable security practices and procedures, appropriate to the nature of the information, to protect a username or email address in combination with a password or security question and answer that would permit access to an online account.

 

  1. The COMPANY shall disclose a security breach as expeditiously as possible and without unreasonable delay to a resident of California: (1) whose unencrypted personal information was, or is reasonably believed to have been, acquired by an unauthorized person, or, (2) whose encrypted personal information was, or is reasonably believed to have been, acquired by an unauthorized person in addition to an encryption key or security credential that could render that personal information readable or usable. The notification may be delayed if a law enforcement agency determines that the notification will impede a criminal investigation, but shall be made promptly after the law enforcement agency determines that it will not compromise the investigation.

 

  1. Security breach notification shall be written in plain language titled “Notice of Data Breach,” containing information under the following headings: “What Happened,” “What Information Was Involved,” “What We Are Doing,” “What You Can Do,” and “For More Information.” The format is to be designed to call attention to the nature and significance of the information it contains, with titles and headings in the notice clearly and conspicuously displayed. The text of the notice shall be no smaller than 10- point type.

 

  1. DATA BROKERS

 

Where the COMPANY collects and sells the personal information of a consumer with whom the business does not have a direct relationship to third parties for monetary or other valuable consideration is required to register annually with the Attorney General as a Data Broker and meet the statutory requirements of a Data Broker.

 

CONTACT US

If you have any questions or need to contact us, please do so at privacy@Netizen.co or at: 

 

Netizen, LLC

5550 Glades Road, Ste 522.  Boca Raton, FL 33431