1. General

This Privacy Notice for California Residents supplements the information contained in A360 Media’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Any other defined terms have the meaning ascribed to them in our Privacy Policy.

2. Information We Collect

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, A360 Media’s websites have collected the following categories of personal information from its consumers within the last twelve (12) months:

Please note that personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

A360 Media obtains the categories of personal information listed above from the following categories of sources both directly and indirectly, as described in our Privacy Policy.

Please note that some personal information may be collected from you in connection with your purchase of or registration for our products and services on third-party websites. For example, our online magazine subscription forms, which capture certain personal information, are hosted by our fulfilment partners. Such personal information is then shared with A360 Media and used in accordance with “Use of Personal Information” below.

3. Sharing Personal Information

A360 Media may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see “Personal Information Sales Opt-Out and Opt-In Rights”). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

3.1 Sales of Personal Information.

• (a) In the preceding twelve (12) months, A360 Media has sold the following categories of personal information:
  • Identifiers.
  • Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Commercial information.
  • Internet or other similar network activity.
  • Geolocation data
• (b) In the preceding twelve (12) months, A360 Media has sold personal information to the following categories of third parties:
  • Advertising revenue partners (including analytics providers).
  • Third-party social media applications.

Please note that A360 Media does allow advertisers to buy email campaigns; however, any promotional emails from third parties are sent to users by A360 Media, and there is no sale of personal information to third parties.

3.2 Sales of Personal Information.

In the preceding twelve (12) months, A60 Media has not disclosed any categories of personal information for a business purpose.

4. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes such rights and explains how to exercise them.

4.1 Access to Specific Information and Data Portability Rights. You have the right to request that A360 Media disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. The specific pieces of personal information we collected about you (also called a data portability request).
6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
   1. sales, identifying the personal information categories that each category of recipient purchased; and
   2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

4.2 Deletion Request Rights. You have the right to request that A360 Media 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 “Exercising Access, Data Portability, and Deletion 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:

7. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
8. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
9. Debug products to identify and repair errors that impair existing intended functionality.
10. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
11. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
12. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
13. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
14. Comply with a legal obligation.
15. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

4.3 Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Submitting a request through a webform available by emailing us at privacy@a360media.com.
• Calling us at (888) 914-9661

Only you, or someone legally authorized 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:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4.4 Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain 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.

4.5 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 to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request by calling us at 1 (888) 914-9661. You may also submit a request through a webform available by emailing us at privacy@a360media.com Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

In the event that A360 Media does provide a CCPA-permitted financial incentive program that results in different prices, rates or quality levels, such program 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.

6. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents who use our websites to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via the contact information listed in “Contact Information” below.

7. Changes to Our Privacy Notice

A360 Media reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our websites and update the notice’s effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

8. Contact Information

If you have any questions or comments about this notice, the ways in which A360 Media collects and uses your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: privacy@a360media.com
Phone: 1 (888) 914-9661