California Privacy Notice
Effective Date: January 1, 2020.
As of the Effective Date, this Privacy Notice (the "California Notice") supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").
This California Notice describes how we collect, disclose, process and otherwise use personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA")
Unless otherwise expressly stated, all terms in the California Notice have the same meaning as defined in our Privacy Policy or as defined in the CCPA.
Personal Information Definition
The term "personal information" in this California Notice 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. The term does not include information that is publicly available in government records, is de-identified, aggregated or anonymized information that is held in a form that does not provide for it to be associated with an individual, relate to any job applicants, employees, contractors or MealPal employees. Personal information also excludes any information excluded from the scope of the CCPA. Terms used in this California Notice have the same meaning as their definition in the CCPA.
Collection And Use Of Personal Information
We collect personal information in connection with our Platform and Services for various purposes. For example, we use personal information to:
- Communicate with you
- Develop and implement marketing and promotional activities
- Process your subscription renewals, provide customer service and/or provide the MealPal service
- Improve our product offering and come up with new products and services
- For other business and commercial purposes as described in our Privacy Policy
Please review the following sections of the Privacy Policy to learn more about the personal information we collect and the purposes for which we collect it: "Collection Of Information" and "Information Use."
In the last 12 months, we have collected the following categories of personal information:
| Personal Information Category | Categories of Sources |
|---|---|
| Identifiers, such as name, address, phone number, email address or other similar items |
|
| California Customer Records, such as your name, address, phone number, credit card number (including the three or four digit validation code for your credit card) |
|
| Protected Classification Characteristics, such as age, gender or demographic group |
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| Commercial Information, such as your ordering history, records of preferences and tendencies, and account status |
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| Internet/Network Information, such as your browsing history, search history, and information about your interaction with the Site |
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| Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (longitude and/or latitude) |
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| Sensory Information, such as recorded calls with our customer service teams |
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| Inferences, including information generated from your use of the Site reflecting your preferences |
|
Sharing And Disclosure Of Personal Information
As further described in the section called "Information Sharing and Disclosure" in our Privacy Policy, we share personal information with third parties for business purposes, or we may "sell" your personal information to third parties, subject to your right to opt out of those sales (see Exercise Your Right to Opt-out below). The CCPA defines "sell" broadly to include many different types of data disclosures or data sharing to third parties for monetary or other valuable consideration. While MealPal may disclose or otherwise share your personal information with select third parties, we do not sell your data to third parties in the traditional sense of the phrase, meaning we do not collect, compile and then sell your data to data brokers, data resellers or other similar parties.
The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Our affiliates
- Restaurant partners
- Employers in instances where a customer is part of an employer sponsored program
- Our service providers and contractors
- Marketing and promotional partners
- Ad networks and advertising partners
- Analytics providers
- Social networks
We may also disclose personal information to third parties at your direction or upon your request, in connection with a corporate business transaction, or to comply with legal or contractual obligations, as described in our Privacy Policy.
In the last 12 months, we have used data as follows:
| Personal Information Category | Disclosed for a business purpose | Disclosed for Sale |
|---|---|---|
| Identifiers | yes | yes |
| California Customer Records | yes | yes |
| Protected Classification Characteristics | no | no |
| Commercial Information | yes | yes |
| Internet/Network Information | yes | no |
| Geolocation Data | yes | no |
| Sensory Information | no | no |
| Inferences | no | no |
In addition, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including Internet / Network Information, Geolocation Data, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights (collectively, the "California Privacy Rights") in relation to the personal information about you that we have collected (subject to certain limitations at law):
| Privacy Right | Description |
|---|---|
| Right to Know | You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
|
| Right to Delete | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| Right to Opt-out | You have the right to direct us not to sell (as that term is defined by the CCPA) personal information we have collected about you to third parties now or in the future. |
| Right to Non-Discrimination | If you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information. That is, if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
How To Exercise Your California Privacy Rights
Exercise Your Right to Know or Right to Delete
You may submit a request to exercise your California Privacy Rights through the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account. We will only use personal information provided in connection with a California Privacy Rights request to review and comply with your request. You may also designate an authorized agent to make requests on your behalf. In order to be able to act, authorized agents must submit a request using the email address below and provide sufficient evidence to demonstrate that the requestor is an authorized agent with written permission to act on your behalf.
In certain circumstances, we may decline a request to exercise the Right to Know or Right to Delete described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To exercise your Right to Know and/or your Right to Delete, please submit a request by emailing [email protected] with the subject line "California Privacy Rights Request".
Exercise Your Right to Opt-out
Unless you have exercised your Right to Opt-out, we may disclose or "sell" your personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy policies. Remember, CCPA defines data "sales" broadly. While MealPal may disclose or otherwise share your personal information with select third parties, we do not sell your data to third parties in the traditional sense of the phrase, meaning we do not collect, compile and then sell your data to data brokers, data resellers or other similar parties.
To exercise the Right to Opt-out of personal information sales, please submit a request by emailing [email protected] with the subject line "California Privacy Right to Opt-out".
You do not need to create an account with us to exercise your Right to Opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Updates To This California Notice
We will update this California Notice from time to time. When we make changes to this California Notice, we will change the "Effective" date at the beginning of this notice. All changes shall be effective from the date of publication unless otherwise provided in the notification. If you do not cancel your Account before the date the revised California Notice becomes effective, you will be subject to the revised California Notice.
Contact Us
If you have any questions or requests in connection with this California Notice or other privacy-related matters, please send an email to [email protected].
Inquiries may also be sent to:
MealPal, Inc.
Attention: California Privacy
264 W. 40th Street, Unit 1303,
New York, NY 10018.