Last Updated: May 30, 2024
This California Consumer Privacy Act Notice (“Notice”) is provided by Babadan Labs, an LLC incorporated in Delaware (hereinafter referred to as “Babadan Labs”, “Reletter”, the “Company”, “we” or “us”).
This Notice explains how we collect, use, retain, and disclose personal information about California residents. The Notice also explains certain rights that California residents have under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”).
The CCPA only applies to information about residents of California. If you are not a resident of California, you may submit a request and we may process it, as described in this Notice, even though the CCPA does not require us to do so. In accepting, processing, and responding to requests by individuals who are not California residents, we will apply all the same limitations and exceptions under the CCPA to those requests as apply to requests made by California residents. We reserve the right to change or stop the practice of accepting requests from U.S. individuals who are not California residents.
Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This information is referred to in this Notice as “Personal Data.”
We collect Personal Data in a variety of contexts. For example, we collect Personal Data to provide newsletter database, monitoring, and reporting products and services, for our human resource purposes, and vendor management purposes.
The Personal Data that we collect about a specific California resident will depend on, for example, our relationship or interaction with that individual.
During the past 12 months, we have collected the following categories of Personal Data.
The sources from which we collect Personal Data depend on, among other things, our relationship or interaction with a specific California resident. The information below lists the categories of sources from which we collect Personal Data in different contexts.
The categories of third parties to whom we disclose Personal Data about a specific individual depend on, among other things, our relationship or interaction with a specific California resident.
Such third parties include:
We will keep Personal Data no longer than necessary to fulfill the purposes described in this Notice. Under our record retention policy, we are required to destroy Personal Data after we no longer need it according to specific retention periods. However, we may need to hold Personal Data beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.
The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration. Reletter does not sell and has not, within at least the last 12 months, sold Personal Data, including Sensitive Personal Data that is subject to the CCPA’s sale limitation. As of January 1, 2024, we do not share Personal Data for cross-context behavioral advertising within the scope of CCPA. We have no actual knowledge that we sell or share Personal Data of California residents 16 years of age and younger.
If you are a California resident, you have the right to request that we:
In addition, you have the right to be free from discrimination by a business for exercising your CCPA privacy rights, including the right as an employee, applicant, or independent contractor not to be retaliated against for exercising your CCPA privacy rights.
If you are a California resident, you can make a Request to Know, Delete, or Correct by submitting your request to [email protected].
When you make a Request to Know, Delete, or Correct, we will attempt to verify that you are who you say you are. For example, we will attempt to match information that you provide in making your Request with other sources of similar information to reasonably verify identity.
Privacy and data protection laws, other than the CCPA, may apply to some of the Personal Data that we collect, use, and disclose. When these other laws apply, Personal Data may be exempt from, or outside the scope of, a request to Know, Delete, or Correct. As a result, we may decline all, or part of your Request related to exempt Personal Data. This means that we may not provide some, or all, of this Personal Data when you make a Request to Know. Also, we may not delete or correct some, or all, of this Personal Data when you make a Request to Delete or Correct.
The types of Personal Data described above are examples. We have not listed all types of Personal Data that may not be included when we respond to or process Requests to Know, Delete, or Correct.
In addition to the above examples, we may not include Personal Data when we respond to or process Requests to Know, Delete, or Correct when the CCPA recognizes another exception. For example, we will not provide the Personal Data about another individual when doing so would adversely affect the data privacy rights of that individual. As another example, we will not delete Personal Data when it is necessary to maintain that Personal Data to comply with a legal obligation.
We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Data subject to the request.
Depending on the nature of your request, we may have to verify your identity when you contact us. We do this by:
We do not verify your identity when you make a request to opt-out of or limit sharing (if the latter is applicable). However, we may ask for the information necessary to complete the request.
We will only use personal information provided in your request to verify your identity or authority to make the request. If, however, we cannot verify your identity based on the information already maintained by us, we may request additional information from you or your authorized representative, which will only be used for the purposes of security, fraud-prevention, or verifying your identity and authority to exercise your rights.
We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days) and give you the reason for the extension of time.
If you are a California resident, you may authorize an agent to make a request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by contacting [email protected]. As part of our verification process, we may request that you provide, as applicable:
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a deidentified fashion and will not attempt to re-identify the information.
We may change or update this Notice periodically. Please visit this page regularly to view our most up to date notice.
If you have any questions or concerns about Reletter’s privacy policies and practices, please contact us at [email protected].