California Privacy Notice
This California Privacy Notice supplements the information contained in the Privacy Policy of MNI ("MNI", "we", "us", "our"). Though MNI does not meet any of the legal thresholds, we have adopted this statement to voluntarily comply with the California Consumer Privacy Act of 2018 (the "CCPA"), as amended with the California Privacy Rights Act of 2020 ("CPRA"), and other California privacy laws, and it applies solely to California residents ("consumers", "you"). Any capitalized terms in the CCPA have the same meaning when used in this notice.
Collection of Personal Information
In the preceding twelve (12) months, we have collected the following categories of Personal Information:
Identifiers
• Full name
• Email address
• Phone numbers
• Gender
• Credit or debit card numbers (only for customer payments)
Sources of information:
• Directly from consumer or employer
• Publicly available information
• From website users / customers
• From third parties / our partners
Internet or other electronic network activity information
• Internet Protocol address
• Interactions with our Sites
Sources of information:
• Directly from consumer's activity on our Sites by cookies or other tracking technologies.
Employment-related information
• Job title
• Company postal address
• Company email address
• Company phone numbers
Sources of information:
• Directly from consumer or employer
• Publicly available information
• From website users / customers
• From third parties / our partners
Please review Section 3. of our Privacy Policy for more information on the business purpose for collecting this information.
Disclosure of Sale of Personal Information
In the preceding twelve (12) months, MNI has disclosed all the above-mentioned categories of Personal Information with our service providers for a business purpose. The service providers include those that provide us with information technology, marketing, accounting, and legal services.
MNI sells information from our Business Databases to our customers for the most common purposes of procurement, sourcing, quoting, purchasing, vendor selection, sales, marketing, executive recruiting, mergers/acquisitions, and market research. The personal information we store in this database are: full name, job title, gender, company email address and/or phone number, company name, and city. For more information about this database please visit www.mni.net.
In the preceding twelve (12) months, we have sold the following categories of personal information for a business purpose:
Identifiers
• Professional or employment-related information
We do not sell the personal information of our customers or of any minors.
Your Rights Under CCPA
The CCPA provides California residents with certain rights regarding their Personal Information.
Right to Know / Disclosure
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. Once we have received and verified your request, we will disclose, in accordance with your request:
• The categories or specific pieces of information we collected about you.
• The categories of sources from which your information was collected.
• The categories of third parties to whom we disclosed or sold your information.
• The categories of information that we disclosed or sold about you.
• Our business or commercial purpose for collecting or for selling your information.
Deletion Request Rights
You have the right to request that we delete your Personal Information that we have collected and retained. Once we receive and verify such a request, we will delete your information from our records, unless retaining that consumer's information is necessary for us or for our service providers to:
• Complete the transaction for which we collected the personal information, provide a good or service which that consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing or intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (California Penal Code § 1546).
• 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on their relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which it was provided.
Right to Opt Out
You have the right to opt-out of sale of certain information subject to the CCPA by requesting that we do not sell your Personal Information. While MNI makes a good faith effort to accommodate opt-out requests, please note that when you exercise your right to opt-out, your request covers removing personal information that is on our systems at the time of the request. At present, we do not have an effective way to guarantee that information about you will not be rediscovered in another form or from a different source. If you find that your Personal Information has been rediscovered, please submit a new opt-out request.
Exercising Your Rights
How to make a request
To exercise any of your rights stated above, you may submit a request to us at:
MNI
Attention: Legal
1633 Central Street
Evanston, IL 60201
Email Legal
Only you or a person authorized to act on your behalf may make a request related to your Personal Information. The request must:
• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Provide sufficient information to allow us to reasonably verify you are a resident of the state of California.
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We will not respond to your request or provide you with information if we are unable to verify your identity or authority to make the request. 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.
You may only request for a copy of your data from MNI twice within a 12-month period.
Authorized Agents
If you would like to use an authorized agent to submit a request on your behalf under the CCPA, the following are required:
• You must provide the authorized agent signed permission to make this request.
• You verify your identity directly with us.
• You provide confirmation that you have provided the authorized agent permission to submit the request.
The above does not apply when you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465.
Our Response
We shall confirm the receipt of any request for deletion or disclosure within 10 days.
We will respond to a verifiable consumer request within 45 days of its receipt. Should we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. If we cannot comply with the request, the response we provide will also explain the reasons for our inability to do so.
We will not charge a fee to process or respond to you request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will provide you with the reasons for our determination and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against a consumer for exercising any CCPA rights.
Metrics
Metrics as of January 2024 for requests for disclosure, deletion, and opt-out of sale in the calendar year 2023.
• Total Number of Requests: 0
• Number of Requests Complied with in Full: N/A
• Number of Requests Complied with in Part: N/A
• Number of Requests Denied: N/A
• Median Number of Days to Respond: N/A
Privacy Policy Updates
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 periodically.
Last Updated: January 2024
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