California Notice of Collection and Other U.S. State Privacy Notices
(Effective November 20, 2023)
Current State of U.S. Privacy Laws
As of the Effective Date of Zultys’ Privacy Policy, a total of thirteen U.S. states have passed comprehensive data privacy laws in the United States: California, Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Texas, Florida, Montana, Oregon, and Delaware. Of those thirteen, California, Colorado, Connecticut, and Virginia’s laws are currently effective.
California Residents
This section applies solely to California residents and supplements our Privacy Policy located here: https://www.zultys.com/privacy-policy/.
California Notice of Collection and Disclosure of Personal Information.
This “Notice of Collection” satisfies the requirements contained in California Code of Regulations Section No. 7012 of providing California residents notice “at or before the point of collection of any personal information”.
Categories of Personal Information About Consumers, Including Categories of Sensitive Personal Information, To Be Collected.
We may collect and disclose or may have collected and disclosed your Personal Information to certain categories of third parties, as described in the table below.
Category of Personal Information | Examples | Possibly collected or shared for a business purpose in the last 12 months | Disclose to Third Parties |
A. Identifiers | Real name, alias, postal address, email address. | Yes | · Our reseller partners · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials where required or permitted by law |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Identifiers listed in the preceding category A and subsequent category I, and signature, social security number, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, or any other financial information, medical information, health information. | Yes | · Our reseller partners · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials |
C. Protected classification characteristics under California or federal law. | Age, marital status, medical condition, gender, veteran or military status. | No | Not Applicable |
D. Commercial Information | Products or services purchased, consumer history | Yes | · Our reseller partners · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials |
E. Biometric information | N/A | No | Not Applicable |
F. Internet or other similar network activity. | Browsing and search history, usage of, and information regarding your use of our applications or website. This information may be used to create anonymous data to help us better understand customer preferences and needs as well as troubleshoot network related issue | Yes | · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials |
G. Geolocation data. | City and state location of your device, which may include GPS-based, WiFi based, or cell-based location information. You can disable collection of location information by our app at any time in your mobile device settings. | No | Not Applicable |
H. Sensory data. | Audio recordings of calls when you call our customer service, and Internet and electronic network activity, as described above. You are notified at the beginning of a call whether the call is being recorded when required by law | Yes | · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials |
I. Professional or employment-related information. | Resume and employment application information. | Yes | · Law enforcement authorities or other government officials |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). | Where applicable, student information related to eligibility for benefits. | No | Not Applicable |
K. Inferences drawn from other personal information. | Inferences drawn from (1) the information we collect when you visit our website, use our app, or interact with our tools, widgets or plug-ins, (2) information we collect from reimbursement claims, and (3) information about user preferences and behavior that we collect on our website and mobile app to create a profile about a user reflecting the user’s preferences, characteristics, predispositions, behavior, and abilities. | Yes | · Our reseller partners · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officials |
L. Sensitive personal information. | Identifiers listed in the preceding category B and precise geolocation, racial and ethnic origin (when hired for a position), the contents of communications where Zultys is not an intended recipient. | Yes | · Our subsidiaries and affiliates · Service providers · Law enforcement authorities or other government officialsBusiness Purposes for Disclosures of Collected Personal Information. |
Business Purposes for Disclosures of Collected Personal Information.
In addition to the purposes outlined in Section 6 of our Privacy Policy entitled “Our Business Purposes and Lawful Bases for Processing Personal Data”, we collect and may disclose collected Personal Information for the following business or commercial purposes:
- To audit our interactions with you to ensure compliance with applicable law and to measure the effectiveness of our products and services;
- To detect, prevent, and prosecute harmful, fraudulent, or illegal activity;
- To identify and repair bugs on our Websites or mobile applications;
- To provide Services, such as customer service, order fulfillment, and payment processing, which we either conduct or engage service providers to conduct on our behalf;
- For research and development;
- To further our business goals, including to advertise our products and services; and
- For quality assurance.
Collection and Use of Sensitive Personal Information
Subject to your privacy selections, your consent, and depending on the products and Services you use and your choices, we may collect certain categories of Personal Information that may be used to infer characteristics about consumers. Some of these categories used to infer characteristics about consumers may be considered “Sensitive Personal Information” under California law, such as a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, or a consumer’s precise geolocation to operate our Services (including those who use our 911/emergency call capabilities).
You have the right to limit the use or disclosure of your Sensitive Personal Information to the following types of activities, in accordance with applicable U.S. state data privacy laws, including CCPA:
- Perform the Services or provide the products and Services you reasonably expect
- Help ensure the security and integrity of our Services, systems, and data, to combat malicious deceptive, fraudulent, or illegal acts, and to protect the physical safety of individuals, to the extent the processing is reasonably necessary and proportionate.
- For short-term transient use (including non-personalized advertising), so long as the Personal Information is not disclosed to a third party, is not used for profiling, and is not used to alter an individual’s experience outside the current interaction with Zultys;
- Perform Services on behalf of Zultys, such as maintaining accounts, providing customer service, processing, or fulfilling orders/transactions, verifying customer information, processing payments, providing financing, providing analytics, providing storage, and similar services.
- Providing government-mandated reports, paying taxes and regulatory fees
- Undertake activities to verify or maintain the quality or safety of, or improve, upgrade, or enhance a Service or device owned or controlled by Zultys.
- Collect or process Sensitive Personal Information where the collection or processing is not for inferring characteristics about the individual.
- Any other activities in accordance with any future regulations that are issued under U.S. state data privacy laws including CCPA.
We only use or share your Sensitive Personal Information for the purposes specified above. This is done either with your consent or as allowed or mandated by relevant laws. Therefore, we do not provide options to restrict the usage of sensitive data.
Sale or Sharing of Personal Information
We do not sell or share your Personal Information for monetary or other valuable consideration. We do not sell or share “Sensitive Personal Information”.
Selling or Sharing Personal Information of Residents Age 16 or Under
We do not have actual knowledge that we sell or share the Personal Information of minors under 16 years of age. We do not sell or share “Sensitive Personal Information”.
Length of Time We Intend to Retain Collected Personal Information.
Zultys intends to retain the Personal Information and Sensitive Personal Information it collects to fulfill all the “Business Purposes” described in this Notice of Collection and Section 10 of the Privacy Policy entitled “How Long Do We Retain Your Personal Data”?
Financial Incentives
We do not offer you any financial incentives such as discounts and special offers in exchange for the provision of your contact information and identifiers such as your name, email address, and/or mobile phone number.
Your Rights and How to Exercise Them
If you are a California resident, you have the right to:
- Request, twice in 12 months, access to the Personal Information we process about you: this right entitles you to know whether we hold Personal Information about you and, if we do, to obtain information on and a copy of the specific pieces and categories of Personal Information.
- Request a rectification of your Personal Information: this right entitles you to have your Personal Information corrected if it is inaccurate or incomplete.
- Object to the processing of your Personal Information: this right entitles you to request that Zultys no longer process your Personal Information.
- Request the erasure or deletion of your Personal Information: this right entitles you to request the erasure or deletion of your Personal Information, including where such Personal Information would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your Personal Information: this right entitles you to request that Zultys only processes your Personal Information in limited circumstances, including with your consent.
- Request portability of your Personal Information: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your Personal Information, or request Zultys to transmit such Personal Information to another data controller.
- Request to opt-out of the sale of your Personal Information or sharing of your Personal Information for cross-context behavioral advertising purposes (if applicable).
You can exercise your rights by submitting a request in the manner described in the “Contact Us” Section 15 of the Privacy Policy. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. To ensure you are the owner of the email address, you must respond to a confirmation email that we will send to such email address. In some cases, we may ask that you provide additional information to verify your identity. You may also designate an authorized agent to request on your behalf. The authorized agent may submit the request in the manner described in the “Contact Us” Section 15 of the Privacy Policy and will be required to provide proof that they have been authorized to act on your behalf. If the authorized agent does not provide such proof, you will be required to confirm your identity and the authenticity of the request.
The execution of any of the requests above can limit our ability to provide the Services.
We will not discriminate against you on account of your exercise of your California privacy rights.
If you would like us to read this Privacy Policy to you, please contact us at 1-408-328-0450.
If you choose to exercise any of your rights under CCPA, we will not charge you different prices or provide different quality of services unless those differences are related to our ability to use your Personal Information or otherwise permitted by law.
For this reporting period, Zultys does not qualify for the CCPA 11 CCR § 999.317(g) reporting requirement.
To the extent that the processing of your Personal Information is based on your consent, you have the right to withdraw such consent at any time by contacting us at privacy@zultys.com. Please note that this will not affect Zultys’ right to process Personal Information obtained before the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
If, despite our commitment and efforts to protect your Personal Information, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to Zultys first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against Zultys with a competent court (either in the country/State where you live, the country where you work, or the country where you deem that data privacy law has been infringed).
Please contact us to exercise any of your rights at privacy@zultys.com, or as described in Section 15 of our Privacy Policy.
If you would like to exercise your erasure, rectification, or access rights about your data as a job applicant, you may also click privacy@zultys.com. Any other rights can be exercised by contacting privacy@zultys.com.
Colorado, Connecticut, and Virginia Residents
This section applies solely to Colorado, Connecticut, and Virginia residents and supplements our Privacy Policy above.
If you are a Colorado, Connecticut, or Virginia resident, you have the right to:
- request access to, or correction or deletion of, your Personal Information; or
- opt out of the processing of your Personal Information for targeted advertising purposes or the sale of your Personal Information.
You can exercise your rights by submitting a request through our privacy email alias at privacy@zultys.com. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. To ensure you are the owner of the email address, you must respond to a confirmation email that we will send to the email address. In some cases, we may ask that you provide additional information to verify your identity. You may appeal our decision concerning a request you have submitted by contacting us at privacy@zultys.com.
Illinois Residents
This section applies solely to Illinois residents and supplements our Privacy Policy above.
As indicated in our Privacy Policy, we do not collect biometric information such as facial geometry when you use certain of our video Services.
Utah Residents
This section applies solely to Utah residents and supplements our Privacy Policy above.
If you are a Utah resident, you have the right to:
- request access to your Personal Information;
- request the deletion of the Personal Information you have provided to us;
- opt out of the processing of your sensitive information; or
- opt out of the processing of your Personal Information for targeted advertising purposes or the sale of your Personal Information. Certain advertising practices, such as those described in the “Purposes for Which We Process Your Personal Data” may be deemed targeted advertising.
You can exercise your rights by submitting a request through our privacy email alias at privacy@zultys.com. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you. To ensure you are the owner of the email address, you must respond to a confirmation email that we will send to the email address. In some cases, we may ask that you provide additional information to verify your identity.
We do not use your Personal Information for targeting advertising purposes nor do we sell your Personal Information.
