NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy notice that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For purposes of this “Notice to California Residents” section “Personal Information” means personal information covered by the CCPA
Right to Know About Personal Information Collected, Disclosed, or Sold
Your “Right to Know”
If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This Right to Know includes the right to request any or all of the following:
- Specific pieces of Personal Information that we have collected about you;
- Categories of Personal Information we have collected about you;
- Categories of sources from which the Personal Information was collected;
- Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
- Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
- The business or commercial purpose for collecting or, if applicable, selling Personal Information.
The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
How to Submit a Right to Know Request
You may submit a request to know by emailing us at email@example.com or by calling us at 1-866-778-624.
Our Process for Verifying a Right to Know Request
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.
We will verify your identity as follows:
Right to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two pieces of Personal Information that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
Right to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual, or the authorized representative of the individual, whose Personal Information is being requested.
Collection of Personal Information
The CCPA defines “business purposes” to mean use of Personal Information for the business’ operational purposes, specifically:
- (1) Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
- (2) Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- (3) Debugging to identify and repair errors that impair existing intended functionality;
- (4) Short-term, transient use, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- (5) Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
- (6) Undertaking internal research for technological development and demonstration; and
- (7) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device.
The CCPA defines “commercial purposes” to mean “to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.”
For purposes of the below chart, we will refer to the business purposes by their above numbers and use the number (8) to reference the definition of commercial purposes.
We share Personal Information, as further specified in the chart below, with the following categories of third parties:
“Marketing Partners” means business partners, such as when you choose to enroll in their services or participate in their promotions or loyalty programs.
“Online Tool Providers” means third parties who offer a specialized service in connection with Personal Information.
“Others” means law enforcement, third parties we are required by law to disclose Personal Information to, or other third parties to whom we otherwise disclose Personal Information to protect the legal rights, property, or safety of Troon or others.
“Service Providers” means third parties that assist us with providing our products and services, including IT, storage, business operations, and marketing services.
“Social Networks” means social networks where Troon maintains an account.
“Troon Affiliates” means other entities controlling, controlled by, or under common control with Troon.
“Troon-Branded Partners” means third parties authorized to offer goods or services under the Troon name.
“Troon-Managed Properties” means third party owners or managers of applicable properties.