California Privacy Notice

This California Privacy Notice supplements the information contained in the Privacy Policy of Pipl, Inc. (“Pipl,” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“Consumer(s), ” as defined in the California Consumer Privacy Act of 2018, or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the related regulations and other applicable California privacy laws. Any capitalized terms in the CCPA have the same meaning when used in this notice.

1. General Information.‍

‍To learn about our commitment to privacy, please visit our privacy center.

2.  Personal Information We Collect.

When referring to Personal information Pipl collects about you, it is important to distinguish between two classes of information:
‍
“Public Data” is publicly available Personal Information we collect about you from (a) the Internet (for example, news articles and blog posts) or (b) other publicly available sources, such as phone books, public records, business contact, and other professional listings.

“Private Data” is Personal Information you provided to us or we collected in our internal systems as part of providing you with our services (for example, your account email and name, billing information, or customer support records)

We collect the following categories of Personal Information from Consumers:

3. Categories of Sources

We obtain the categories of personal information listed above from the following categories of sources:

• Online: Publicly available Personal Information collected from pages, documents, databases, or applications available on the world wide web.
• Offline: Personal Information licensed from providers of publicly available information such as phone books publishers, public records aggregators, business & professional contacts providers.

Directly and indirectly from activity on our website or other systems. For example, from submissions through our website (such as prospective customers seeking information or help) or website usage details automatically collected.

4. Uses of Personal Information

We may use or disclose Personal Information we collect for one or more of the following business purposes:

We provide or sell Public Data to the users of our Services. For example, when our Customer uses one of our services to validate identity information, we provide publicly available personal information on that individual.

Our services are used primarily for identity verification, compliance, fraud prevention, contact enrichment, and investigations.

We use this data to provide our Services to our Customers, or improve our services, or provide relevant information and offers to our customers and prospects. For example, when you use our website or any of our services, we collect information about how often and what function you are using so that we can improve the quality of our service.

We never knowingly sell or publicly disclose Personal Information that is associated with a minor individual.

Please read our Privacy Policy to learn more.

5. Your Rights and Choices.

The CCPA provides Consumers who are California residents with certain rights regarding their Personal Information. This section describes your CCPA rights. The following sections explain how to exercise those rights. 

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. You may request either information about the categories of Personal Information that we collect about you and/or specific pieces of Personal Information.  Once we receive your request and confirm your identity, we will disclose to you, in accordance with your request:

• The categories of Personal Information we have collected about you.
• The categories of sources for the Personal Information we have collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we have collected about you.
• If we sold or disclosed your Personal Information for a business purpose we will identify the Personal Information categories that each category of recipient obtained.

You have the right to request that we delete any of your Private Data that we have collected and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will delete (and direct our service providers to delete) your Private Data from our records, unless one of the exceptions below applies. 

We may deny your request to delete if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provided 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech ensures the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Sec. 1546 et seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You have the right to request that we not sell your Personal Information. While we are not required to verify your identity, we may deny a request if we have a good-faith, reasonable, and documented belief that the request is fraudulent.

NOTE: While we make a good faith effort to accommodate opt-out requests about Personal Information, due to the nature of  Pipl’s technology and the ever-changing nature of the internet, opting-out of certain information does not guarantee that similar information will not appear in another form, at a different source or in a new record. In collecting publicly available information, Pipl is essentially acting as a search engine, very much like Google or Bing, constantly scanning publicly available sources for identity information than providing identity solutions to customers based on that information. When you exercise your right to opt-out, your request covers removing Personal Information that is currently on our systems. At present, we do not have an effective way to apply your request to any Personal Information that we may discover or receive in the future, as new information about you becomes available you may submit a new opt-out request.

6. Exercising Your Opt-out, Disclosure, and Deletion Rights

To exercise your right to know, delete, or opt-out as described above, you may submit a request to us via the following methods:

• Filling this opt-out/removal request form (easiest to fill, expect a quick response)
• Calling us at (877) 616-1115 (phone requests typically require additional steps and take longer to process)
• Initiate a request for disclose/deletion (identity verification required, in some cases, you will be asked to send a copy of your California picture ID)

Only you or a person that you have authorized to act on your behalf may make a verifiable Consumer request related to your Personal Information on your behalf.  You may also make verifiable Consumer requirements 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 enough information that allows us reasonably to verify that you are the person about whom we collected the Personal Information or an authorized representative of the person about whom we collected the Personal Information.
• Describe your request with enough detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request to delete 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 or to the person that you are representing (if you are an authorized representative). We will try to use the information we have about you to verify your identity, if additional verification is required, we may ask you for additional proof of identity such as a copy of your picture ID.

Making a Consumer request does not require you to create an account with us. We will only use Personal Information provided in your request and any information provided to verify your identity in connection with the request, solely to process the request, keeping audit records, verify the requestor’s identity, and/or authority to make the request, and for no other purpose.

If a Consumer uses an authorized agent to submit a request, we may require the following: 1) that the Consumer provide the authorized agent written permission to do so and verify the Consumer's identity directly with Pipl or 2) a power of attorney authoring the authorized agent to act on behalf of the Consumer that is (a) either witnessed by two parties or duly notarized and (b) otherwise complies with the requirements of the California Probate Code, Sections 4000-4465.

Upon receiving a request for disclosure or deletion, we shall confirm receipt thereof within 10 days. Except in instances where we deny the request, confirmation will include information about how we will process the request, including our verification process and the timeline on which the Consumer should expect a response. 

We endeavor to respond to a verifiable Consumer request within 45 of its receipt. We are permitted up to 90 days to respond if we notify you of the extension within 45 days of our receipt of your request. If we require an extension, we will inform you of the reason and the extension period in writing. You are not required to have an account with us to make a verifiable request. We will deliver our written response by mail or electronically at your option.  Any disclosure we provide will cover the 12-month period preceding receipt of the verifiable Consumer request. If we cannot comply with your request, the response we provide will also explain the reasons. For disclosing the data itself, we will provide your Personal Information in a format that is readily available and portable.

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.

7. 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 a different price 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.

8. Annual Report on Requests to Know, Delete and Opt-Out for the calendar year 2023:

* “Respond” means providing a substantive response. It doesn’t include extension notices or other administrative notices.

9. Changes to Our Privacy Notice

We reserve the right to amend this California Privacy Notice and our Privacy Policy at our discretion and at any time without notice. Please check back from time to time.

Last Updated: January 10, 2023