Additional California Privacy Disclosures
Effective as of January 1, 2020
If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as described in under the CCPA).
This supplement provides additional privacy disclosures and informs you of your additional rights as a California resident, and should be read in conjunction with our Privacy Policy.
Personal Information Collected and Processed
Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months:
| Category | Collected |
|---|
| Identifiers | YES |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | YES |
| Protected classification characteristics under California or federal law. | NO |
| Commercial information. | YES |
| Biometric information. | NO |
| Internet or other similar network activity. | YES |
| Geolocation data. | YES |
| Sensory data. | NO |
| Professional or employment-related information. | YES |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | NO |
| Inferences drawn from other personal information. | YES |
Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Xceed obtains the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Websites.
From third-party business partners such as social media sites, ad networks, and analytics providers.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- - To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- - To provide, support, personalize, and develop our Websites, products, and services.
- - To create, maintain, customize, and secure your account with us.
- - To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- - To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- - To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
- - To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
- - For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
- - To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- - As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Xceed's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Xceed about our Website users is among the assets transferred.
- - Xceed 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.
Requests to Exercise Your Rights
RIGHT TO KNOW REQUEST - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:
- - Categories of and specific pieces of personal information we have collected about you.
- - Categories of sources from which we collect personal information.
- - Purposes for collecting, using, or selling personal information.
- - Categories of third parties with which we share personal information.
- - Categories of personal information disclosed about you for a business purpose.
- - If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
To make a verifiable request for information about the personal information we have collected about you, please make a request by emailing us at contact@recruitingbridge.com with the subject "I want to make a download a copy of my data".
RIGHT TO DELETE REQUEST - You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete, please make a request by emailing us at contact@recruitingbridge.com with the subject "I want to permanentely delete my data".
HOUSEHOLD REQUESTS - We currently do not collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.
REQUESTS, GENERALLY - Please note, if you do not have a Xceed account we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the Xceed where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.
REQUESTS MADE THROUGH AGENTS - You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, Xceed has disclosed certain data from the following categories of personal information to the categories of recipients for one or more business purposes:
Service Proders
Usage Data
Payment Data
Sale of Personal Information
Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA. Due to the complexities and ambiguities in the CCPA, we will continue to evaluate some of our third party relationships as we wait for final implementing regulations and guidance. For example, it is currently unclear whether the use of certain types of advertising partners would be considered a sale under CCPA. We provide Usage Data to advertising partners, which enables us to provide you with interest-based advertising. If you prefer not to receive interest-based advertising, please opt out by going to your account privacy settings and using the tailored ads opt out toggle. For more information on interest-based advertising, please see our Privacy Policy and Cookie Policy. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.
How to Contact Us
If you believe your Services Data has been used in a way that is not consistent with this policy, or if you have further questions related to this policy, please contact at:
Xceed Privacy
410 Mill St. Suite 106
Mount Pleasant, SC 29464