Consumer Data Privacy Policy

CALIFORNIA ADDENDUM TO VIAMEDIA CONSUMER DATA PRIVACY POLICY

California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”)

Updated August 22, 2024

Background:

This Addendum applies only to residents of California (“California Consumers”). It is intended to be read in tandem with the primary Viamedia Consumer Data Privacy Policy, and incorporates all defined terms used therein. This Addendum describes how Viamedia collects, uses, and discloses the PII of California residents (“CPII”). CPII does not include, and this Addendum does not apply to, information that is subject to exceptions from the CCPA, such as deidentified information.

Collected Categories and Sources of CPII:

Viamedia has collected the following categories of CPII in the past twelve (12) months: (A) Identifiers; (B) CPII categories listed in the California Customer Records statute; (C) Internet or other similar network activity; (D) Geolocation data, which can be derived from California Consumer’s IP Address and precise geolocation data; (E) Inferences drawn from other CPII; and (F) CPII defined as “sensitive” under the CCPA, including precise geolocation information.

Viamedia may collect or obtain CPII from the sources described in the primary Viamedia Consumer Data Privacy Policy.

Disclosures of CPII for a Business Purpose:

In the past twelve (12) months, we may have disclosed the categories of CPII listed below to the categories of third parties identified below for a business purpose:

Identifiers – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy;
Personal information categories listed in the California Customer Records statute – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy.
Geolocation data – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy;
Internet and other electronic activity information – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy;
Inferences drawn from other CPII – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy;
CPII defined as “sensitive” under the CCPA – with our affiliates, service providers, and as otherwise described in the “Storage, Access, and Deletion of Consumer Data” section of the primary Viamedia Consumer Data Privacy Policy.

Sales of CPII and Sharing of CPII for Cross Context Behavioral Advertising:

Viamedia does not sell CPII in exchange for monetary consideration. However, the CCPA defines “sale” very broadly in a manner that includes disclosing CPII in exchange for any other valuable consideration, and also regulates the “sharing” of CPII with third parties for cross-context behavioral advertising purposes, which means displaying advertising to California Consumers based on CPII obtained or inferred from that California Consumer’s activities over time across different websites, applications, and other online services Viamedia does not operate. Under the CCPA, Viamedia may “sell” or “share,” and Viamedia may in the preceding twelve (12) months have “sold” or “shared,” the following categories of CPII:

Geolocation data as derived from IP address and precise geolocation data.

Viamedia may have sold or shared CPII in each of these categories to or with third parties such as advertising networks that enable or participate in targeted and cross-context behavioral advertising, and analytics providers that provide online tracking technologies that we use to analyze usage of the Services. Viamedia may engage in such sales or sharing for purposes of delivering or facilitating cross-context advertising to California Consumers utilizing the Services and California Consumers utilizing the websites and other online services provided by third parties and performing analytics.

Viamedia does not have actual knowledge that it sells CPII of children who are California residents under 16 years of age or shares the CPII of children who are California residents under the age of 16 for cross-context behavioral advertising purposes.

Use of CPII:

In the past twelve (12) months, Viamedia has used or disclosed the CPII it collects for operational purposes and for one or more of the following business purposes outlined in the “Collection and Processing of PII” section in the primary Viamedia Consumer Data Privacy Policy.

Viamedia does not intend to use CPII defined as “sensitive” under the CCPA for the purpose of inferring characteristics, such as California Consumer preferences or personal interests, about that individual California Consumer. Notwithstanding any provisions of this Addendum and the parent Viamedia Consumer Data Privacy Policy that directly conflict with the following, we only use CPII defined as “sensitive” under the CCPA to perform the services or provide the products California Consumers request, for security and integrity purposes, short-term transient use where the relevant information is not disclosed to a third party or used to build a California Consumer profile, such as to identify California Consumers and California Consumers’ locations when consent is given to collect such data to our collection of precise geolocation data from a California Consumer’s browser, performing services on our behalf, undertaking quality and safety control exercises, and other collection and processing that is not for the purpose of inferring characteristics about individual California Consumers.

Right to Request Deletion:

California Consumers can ask for the deletion of their CPII. If a California Consumer asks for their individual CPII, Viamedia will respect that request and delete their CPII, subject to certain exceptions provided by law, including, but not limited to, the exercise by another California Consumer of their right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to Know:

California Consumers have the right to request to receive certain information about our collection, use, and disclosure of their CPII during the applicable period of time for their request. If Viamedia receives and confirms a verifiable California Consumer request from a California Consumer pursuant to the “How to Exercise California Consumer Rights” section below, Viamedia will disclose to that California Consumer, depending on the scope of the request:

Whether Viamedia collects and uses your CPII;
The categories of CPII we collected about that California Consumer;
The categories of sources for the CPII we collected about that California Consumer;
Viamedia’s business or commercial purpose for collecting CPII about that California Consumer, selling CPII about that California Consumer, or sharing CPII about that California Consumer for cross-context behavioral advertising purposes;
If Viamedia sells that California Consumer’s CPII, shares that California Consumer’s CPII for cross-context behavioral advertising purposes, or discloses that California Consumer’s personal information for a business purpose, a list of the categories of third parties to whom Viamedia sold CPII, shared CPII for cross-context behavioral advertising purposes, or disclosed CPII for a business purpose, as applicable, identifying the categories of CPII established by the CCPA sold, shared, or disclosed to those parties during the applicable period of time for that California Consumer’s request;
The specific pieces of CPII Viamedia collected about that California Consumer;
The categories of third parties with whom Viamedia discloses CPII generally.

Right to Non-Discrimination for the Exercise of a California Consumer’s Privacy Rights:

Subject to certain exceptions, California Consumers have the right to not receive unlawfully discriminatory treatment for exercising their access, data portability, and deletion rights described above.

Other California Privacy Rights:

California Consumers can opt-out of sales or sharing of their CPII for cross-context behavioral advertising purposes by referring to the contact details in the “Update and Contact” section of the primary Viamedia Consumer Data Privacy Policy.

Even if California Consumers opt-out of sales or sharing of their CPII for cross-context behavioral advertising, California Consumers may still see Viamedia’s ads online at other sites and apps, and Viamedia may still base aspects of ads on California Consumer interactions with Viamedia, the Services, and the Website.

Valid Requests:

California Consumers may request to receive a copy of their CPII in readily usable format to the extent technically feasible. California Consumers may request that Viamedia correct CPII about them that is inaccurate, considering the nature of the CPII and the purposes of its processing when that request is addressed.

California’s “Shine the Light” law permits California residents who have an established business relationship with Viamedia to request certain information regarding Viamedia’s disclosures of their personal information (as defined by that law) during the preceding year, if any, to third parties for those parties’ own direct marketing purposes. If a California Consumer is a California resident who has an established business relationship with Viamedia and wishes to exercise their rights under that law, please send a written request by mail to the address provided in the “Update and Contact” section of the primary Viamedia Consumer Data Privacy Policy.

Exercising California Consumer Rights:

To exercise their rights, California Consumers can contact Viamedia by email at the contact in the “Update and Contact” section of the primary Viamedia Consumer Data Privacy Policy. California Consumers may designate someone to submit requests and act on their behalf as an authorized agent. Viamedia may mandate additional requirements for requests submitted through an authorized agent, such as requiring the California Consumer to verify their identity directly with us or to directly confirm the authorized agent’s permission to act on their behalf.

Upon receiving a California Consumer’s request, Viamedia will need to verify their identity to determine they are the same person about whom Viamedia has the information in our system. These verification efforts require Viamedia to ask California Consumers to provide information so that we can match it with information that the California Consumer has previously provided Viamedia. For instance, depending on the type of request submitted, Viamedia may ask the California Consumer to provide certain information so that Viamedia can match the information provided with the information that may already be on file, or Viamedia may contact that California Consumer through a communication method, such as by phone or email, that such California Consumer has previously provided to Viamedia. Viamedia may also use other verification methods as the circumstances dictate. If Viamedia is unable to verify a California Consumer’s identity or authority to make the request and confirm that the personal information relates to that California Consumer, Viamedia may not be able to respond to such request.