Effective: February 1, 2020
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the particular service, product or functionality if that information is necessary to provide you with such service, product or functionality or if we are legally required to collect it.
The CCPA describes several categories of Personal Information. The following chart describes those categories and identifies which categories we have collected during the past 12 months.
|Identifiers||A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, photograph, passport number, current or past job history, or other similar identifiers.||YES|
|Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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.
Note: Some personal information included in this category may overlap with other categories.
|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).||YES|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies||YES|
|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.||NO|
|Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.||YES|
|Geolocation data.||Physical location or movements.||YES|
|Sensory data||Audio, electronic, visual, thermal, olfactory or similar information.||NO|
|Professional or employment-related information||Current or past job history or performance evaluations.||YES|
|Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)||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.||NO|
|Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||NO|
Personal Information does not include:
Information You Provide to Us
We may receive Personal Information directly from you when you interact with our websites, purchase products, interact with us or otherwise provide us with your Personal Information. We may also provide additional notices when collecting information from you about our collection, use and disclosure of that Personal Information. These notices may supplement or clarify our privacy practices with respect to that Personal Information and may provide you with additional choices about how we use that Personal Information.
Personal Information Collected from Third Parties
We may collect your Personal Information from third party business partners such as social media sites, ad networks and analytics providers.
We may also collect your Personal Information from others that refer you to our Service.
Personal Information Automatically Obtained from Your Interactions with the Sites
When you use our Sites, our servers automatically record information that your browser sends whenever you visit a website. This information may include your IP address, browser type or the domain from which you are visiting, the webpages you visit, the search terms you use and any advertisements you interact with.
Like many websites, our Sites also use “cookie” technology to collect additional website usage data and to improve the Sites and our Service. A cookie is a small data file that we transfer to your computer’s hard disk. A session cookie enables certain features of the Sites and is deleted from your computer when you disconnect from or leave the Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Sites. We may use both session and persistent cookies to better understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic routing on out Sites, and to improve our Sites and Services. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all of the services or functionalities of the Sites. For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.
We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or after you visit our Sites, the pages or other content you view or otherwise interact with on our Sites and the dates and times that you visit, access or use our Sites. We may also use these technologies to collection information regarding your interaction with email messages, such as whether you opened, clicked on or forwarded a message, to the extent permitted under applicable law.
Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
Our Sites may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or mobile device, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third party sites or services to which links or access are provided through our Sites. We encourage you to read the privacy policies or statements of the other websites you visit.
Bay Club 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.
We share your Personal Information with the following categories of third parties:
In the past 12 months, Bay Club has disclosed the following categories of Personal Information for a business purpose:
|Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))||YES|
|Protected classification characteristics under California or federal law.||YES|
|Internet or other similar network activity||YES|
|Professional or employment-related information||YES|
|Non-public education information (per the Family Education Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)||NO|
|Inferences drawn from other personal information.||NO|
In the past 12 months, Bay Club has not sold Personal Information.
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.
Access to Specific Information and Data Portability Rights
You have the right to request that Bay Club disclose certain information to you about our collection and use of Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will disclose to you, based on what you request:
Deletion Request Rights
You have the right to request that Bay Club 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 How to Exercise Your 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 providers to:
How to Exercise Your 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 to exercise your access, data portability and/or deletion rights 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. 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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.
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 prior to the date we receive the verifiable consumer request. The response we provide will also provide 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 16 years of age or older, you have the right to direct us not to sell your Personal Information at any time. We do not sell Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
We will not discriminate against you for exercising any of your rights under the CCPA. 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 Civil Code Section 1798.83 permits visitors to our site who 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 us at firstname.lastname@example.org, or you may write to us at:
The Bay Club Company
1 Lombard St.
San Francisco, CA 94111
We welcome your questions, comments and concerns about privacy. Please email us at email@example.com with your feedback pertaining to privacy. You also may write to us at:
The Bay Club Company
1 Lombard St.
San Francisco, CA 94111