Addendum For California Resident’s Privacy Rights

Last updated: September 21, 2021


This CCPA Privacy Policy Addendum (“Addendum”) supplements our Privacy Policy and provides additional information to California residents about how we handle their Personal Information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This Addendum does not address or apply to our collection and processing of data that is exempt from CCPA, including publicly available information lawfully made available by state or federal government records or other Personal Information that is exempt under the CCPA. Please note: This Addendum is intended solely for California consumers, so if you are not a California consumer (this means a resident of California), this Addendum does not apply to you and you should not rely on it.


“Personal Information” (as defined by the CCPA) means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. While our collection, use and disclosure of Personal Information varies based upon our relationship and interactions with you, in this Addendum we describe, generally, how we have collected and disclosed Personal Information about California residents in the prior 12 months (from the Last updated date above).


Categories of Personal Information Collected and Disclosed. The table below identifies the categories of Personal Information we have collected about California residents, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose Personal Information, please see the How We Use Information We Collect and Sharing and Disclosure sections in our main Privacy Policy.




Personal Information Collected Categories of Third Parties to Whom We May Disclose this Information for a business purpose
Categories Description
Identifiers Includes direct identifiers, such as name, alias user ID, username, account number; email address, phone number, address and other contact information; IP address and other online identifiers; and other similar identifiers. service providers • advisors and agents • affiliates and subsidiaries • advertising networks • data analytics providers • data compilers and aggregators • social networks • third party partners • internet service providers • operating systems and platforms • business customer/client
Customer Includes Personal Information, such as name, account name, user ID, contact information, employment information, account number, and other information that individuals provide us in order to purchase or obtain our products and services. service providers • advisors and agents • our affiliates and subsidiaries • business partners who provide services you request
Commercial Information Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. service providers • advisors and agents • affiliates and subsidiaries • advertising networks • data analytics providers • data compilers and aggregators • social networks • third party partners • internet service providers • operating systems and platforms • data brokers • business customer/client
Usage Data Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. service providers • advisors and agents • affiliates and subsidiaries • advertising networks • data analytics providers • data compilers and aggregators • third party partners • social networks • internet service providers • operating systems and platforms
Audio, video and electronic data Includes audio, electronic (other than usage data described above), visual, thermal, olfactory, or similar information such as, call recordings (e.g., of customer support calls). service providers • advisors and agents • affiliates and subsidiaries
Professional information Includes professional and employment-related information such as business contact information and professional memberships. service providers • advisors and agents • affiliates and subsidiaries
Education information Information about an individual’s educational history such as the schools attended, degrees you were awarded, and associated dates. service providers • advisors and agents • affiliates and subsidiaries
Inferences Includes inferences drawn from other Personal Information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads. service providers • advisors and agents • our affiliates and subsidiaries • analytics providers • data compilers and aggregators • third party partners

Sources of Personal Information. As further described in the Information We Collect section in our Privacy Policy, we may collect Personal Information from the following sources:


  • directly and indirectly from the individual or their devices
  • advertising networks
  • data analytics providers
  • data brokers / aggregators
  • social networks
  • public sources
  • customers (including via application program interface (API) or other automated electronic processes)

Personal Information sold. Under the CCPA, a “sale” includes disclosing or making available Personal Information to a third-party in exchange for monetary compensation or other benefits or value. When you download or use any mobile app of one of our customers that is part of the Complementics Network, we will automatically collect information, including Personal Information, about your precise location, your usage of the app and your device’s Advertising ID , in order to share it with other customers of ours.


In general, California residents have the following rights with respect to their Personal Information:


  • Do-not-sell (opt-out): to opt-out of our sale of their Personal Information. While we may “sell” Personal Information as defined by the CCPA, we do not sell Personal Information about California consumers who we know are younger than 16 years old. California residents may opt out of sales of their Personal Information by us as set forth below.
  • Right of deletion: to request deletion of their Personal Information that we have collected about them and to have such Personal Information deleted (without charge), subject to certain exceptions.
  • Right to know: with respect to the Personal Information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):


  •      categories of Personal Information collected;
  •      categories of sources of Personal Information;
  •      categories of Personal Information about them we have disclosed for a business purpose or sold;
  •      categories of third parties to whom we have sold or disclosed for a business purpose their Personal Information;
  •      the business or commercial purposes for collecting or selling their Personal Information; and
  •      a copy of the specific pieces of Personal Information we have collected about them.


  • Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.


Submitting CCPA requests


California residents may submit CCPA requests to opt out of sales, requests to know (access), and requests to delete their Personal Information through one of the following methods:

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform or otherwise provide us with this information via the above toll-free number or email address. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may also submit requests on behalf of consumers using the webform, toll free number or email above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.


Your Privacy Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at [email protected], and include in your request a current California address and your attestation that you are a California resident.


For more information about our privacy practices, you may contact us at [email protected]


Email: [email protected] | Telephone: 312-477-7313 | Address: 1074 W Taylor St #371 Chicago, IL 60607

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