CCPA NOTICE AT COLLECTION

CCPA NOTICE AT COLLECTION

Effective Date: January 1, 2025

HEAD.ID ("we," "us," or "our") collects personal information about California consumers. This notice describes the categories of personal information we collect, the purposes for which we use it, and your rights under the California Consumer Privacy Act (CCPA).

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

A. Identifiers

• Real name, alias, postal address, unique personal identifier
• Online identifier, Internet Protocol address, email address
• Account name, social security number, driver's license number
• Passport number or other similar identifiers

B. Personal Information Categories (Cal. Civ. Code § 1798.80(e))

• Name, signature, social security number, physical characteristics or description
• Address, telephone number, passport number, driver's license
• Insurance policy number, education, employment, employment history
• Bank account number, credit card number, debit card number
• Any other financial information, medical information, or health insurance information

C. Protected Classification Characteristics

• Age (40 years or older), race, color, ancestry, national origin
• Citizenship, religion or creed, marital status, medical condition
• Physical or mental disability, sex, sexual orientation, veteran or military status
• Genetic information (including familial genetic information)

D. Commercial Information

• Records of personal property, products or services purchased, obtained, or considered
• Other purchasing or consuming histories or tendencies

E. Biometric Information

• Genetic, physiological, behavioral, and biological characteristics
• Information used to extract a template or other identifier

F. Internet or Other Similar Network Activity

• Browsing history, search history, information on consumer's interaction
• With a website, application, or advertisement

G. Geolocation Data

• Physical location or movements

H. Sensory Data

• Audio, electronic, visual, thermal, olfactory, or similar information

I. Professional or Employment-Related Information

• Current or past job history or performance evaluations

J. Non-Public Education Information

• Education records directly related to a student maintained by an educational institution

K. Inferences Drawn from Other Personal Information

• Profile reflecting a person's preferences, characteristics, psychological trends
• Predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

SOURCES OF PERSONAL INFORMATION

We collect personal information from:

• Directly from you when you provide it to us
• Automatically as you navigate through our site
• From third parties such as social media platforms, data brokers, and marketing partners
• From public records databases
• From our business partners and affiliates

BUSINESS OR COMMERCIAL PURPOSES FOR COLLECTION

We collect personal information for the following business purposes:

• Auditing related to counting ad impressions and verifying positioning
• Security and debugging to identify and repair errors
• Short-term, transient use where personal information is not disclosed to another third party
• Performing services such as customer service, processing orders, analytics
• Internal research for technological development and demonstration
• Quality and safety maintenance and verification or improvement
• Other commercial purposes consistent with consumer expectations

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

We may share your personal information with:

• Service providers and contractors
• Business partners for joint marketing efforts
• Affiliates and subsidiaries
• Government entities when required by law
• Third parties for business transactions (mergers, acquisitions)

CCPA CONSUMER RIGHTS

California residents have the following rights:

1. RIGHT TO KNOW

• The categories of personal information we collected about you
• The categories of sources from which we collected personal information
• Our business or commercial purpose for collecting personal information
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we collected about you

2. RIGHT TO DELETE Request that we delete any personal information about you that we collected from you, subject to certain exceptions.

3. RIGHT TO OPT-OUT OF SALE We do not sell personal information. If our practices change, we will update this notice and provide you with an opt-out mechanism.

4. RIGHT TO NON-DISCRIMINATION We will not discriminate against you for exercising any of your CCPA rights.

HOW TO EXERCISE YOUR RIGHTS

Submit Requests:

• Online: [Privacy Request Form Link]
• Email: privacy@headid.com
• Phone: 1-800-HEAD-ID1 (1-800-432-3431)
• Mail: HEAD.ID Privacy Rights, [Address]

Verification Process: We will verify your identity before processing your request. You may be asked to:

• Provide identifying information (name, email, phone number)
• Answer questions about your account or recent purchases
• Provide a signed declaration under penalty of perjury

Authorized Agents: You may designate an authorized agent to make a request on your behalf. The agent must:

• Provide proof of written authorization from you
• Verify their own identity
• Be registered with the California Secretary of State (if a business)

Response Time:

• We will acknowledge receipt within 10 days
• We will respond within 45 days (extendable to 90 days with notice)