California Privacy Notice

INTRODUCTION

This Privacy Notice for California residents (“California Privacy Notice”) supplements and is expressly made part of the information contained in Validity’s Privacy Policy and applies solely to site visitors, potential customers, vendor representatives, event/webinar participants, and others who reside in the State of California (“consumers” or “you”).

This California Privacy Policy applies to any of Validity’s websites, as well as to information that we collect off-line (such as call centers, tradeshows, or seminars), except as otherwise set forth in a separate agreement between you and Validity.

Validity fully describes its practices related to processing personal information in the Validity Privacy Policy. In addition, Validity uses this California Privacy Notice (as applicable) to comply with the specific requirements in the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA/CPRA have the same meaning when used in this California Privacy Notice. A reference to “Validity,” “we,” or “us,” is a reference to Validity, Inc.

INFORMATION WE COLLECT

Depending on the context of the collection, Validity may have collected and disclosed the following categories of personal information for business purposes only within the last 12 months (note that the summary table below is based on CCPA enumerated categories, and only includes the categories in scope):

HOW WE COLLECT YOUR INFORMATION

We obtain the categories of personal information listed in the table above from the following categories of sources:

• directly from you, including offline;
• your browser or device;
• through your use of the Sites and Offerings;
• cookies and other similar technologies;
• service providers;
• business partners and affiliates; and
• third parties, in cases where you direct them to share information with us.

For more details about how we use these sources, please refer to our Privacy Policy.

HOW WE USE YOUR INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

• to register you for events or trials;
• to perform the contract that we are about to enter or have entered into with you;
• to improve the content of our Services;
• to deliver interest-based content to you, including marketing and advertising material;
• to carry out research on customer demographics;
• to administer our Offerings, including by monitoring and analyzing traffic and usage patterns;
• to respond to inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Services;
• to send administrative information to you, such as changes to our terms, conditions, policies, or information regarding the Services;
• to personalize your experience on the Sites by presenting products and offers tailored to you;
• to allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, and we suggest you read these rules carefully.

For more information on our reasons for collection and usage of personal information, please refer to our Privacy Policy.

HOW WE MAY DISCLOSE PERSONAL INFORMATION

In the preceding twelve (12) months, we have disclosed the categories of personal information described in the table above for business purposes.

We disclose your personal information with our affiliates, service providers, and agents to carry out our obligations under our contract with you or for business purposes. Before we disclose such information, we enter into a contract with those parties that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except as defined in the contract.

SALE AND SHARE OF PERSONAL INFORMATION

Validity doesn’t sell personal information (including of known minors under 16 years of age) within the meaning of the CCPA/CPRA. We also do not share your personal information for the purposes of cross-context behavioral advertising, as defined under the CCPA/CPRA.

YOUR PRIVACY RIGHTS AND CHOICES

The CCPA and CPRA provide California residents with specific rights regarding their personal information. This section describes your rights as provided by CCPA/CPRA. Please note that some of those rights may not be applicable to our processing of your personal data; however, we wanted to display them here for your general knowledge.

Right to Know

You have the right to request that we disclose to you any personal information that we have collected, sold, or shared about you in the last 12 months.

Right to Correct

You have the right to request correction of any inaccurate personal information that we maintain about you. We will use commercially reasonable efforts to correct your personal information as directed by you, taking into account the nature of the personal information and the purposes of maintaining it.

Right to Request Deletion

You have the right to request the deletion of any personal information we have collected from you, subject to certain exceptions as identified in applicable law.

Right to Non-Discrimination

You have a right to receive non-discriminatory treatment by Validity when exercising of the privacy rights conferred by the CCPA/CPRA. Discriminatory treatment, includes denying goods or services, charging different prices, or providing a different level or quality of service when exercising your privacy rights. Please note, however, that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our Services or engage with you in the same manner.

Right to Opt-out of the Sale or Share

You have a right to direct a business to stop selling or sharing your personal information with third parties.

Right to Limit the Use of Sensitive Personal Information

You have the right to limit how your Sensitive Personal Information is used and disclosed, subject to certain exceptions as identified in applicable law.

Please note Validity doesn’t use or disclose your Sensitive Personal Information for any purposes other than those that are specified in section 7027, subsection (l).

EXERCISING PRIVACY YOUR RIGHTS

Only you, or your authorized agent, may make a verifiable consumer request related to your personal information.

To exercise your Right to Know, Right to Correct or Right to Delete, please submit a request to us by either sending an email to: [email protected] or calling us at: (+1) 800-961-8205 (US toll-free).

The request must be a verifiable consumer request, and so must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information and contain sufficient detail that allows us to properly understand, evaluate, and respond to it.

IDENTITY VERIFICATION

Validity will decide of what pieces of personal information to use for verification based on the information we maintain about you in our systems. We will strive not to collect any additional personal data from you except as necessary to verify your identity.

We will need to know your full name and email address, as associated with Validity. In some cases, we may ask you any of the following:

• to log in to your Validity customer support account, if applicable;
• to provide additional information describing your connection to Validity;
• to verify your identity by providing a “signed” declaration under penalty of perjury.

We may use the following methods to verify your identity: email validation, mobile number validation, fact-based questions, or in-person document identity verification.

We cannot respond to your request or provide you with personal information if (i) we cannot verify your identity or authority to make the request or (ii) we cannot confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make such request.

SUBMITTING VIA AUTHORIZED AGENT

In certain circumstances, you are permitted to use an authorized agent (as defined under the CCPA/CPRA) to submit requests on your behalf.

When you use an authorized agent to submit your request, in accordance with the applicable California law, we may require:

• you to provide the authorized agent written permission to do so;
• the authorized agent to verify their own identity directly with Validity and include a written authorization which you have signed in their request to us; and
• you to confirm directly with Validity that you provided the authorized agent permission to submit the request.

The security and privacy of your personal information is important to us. We may deny a request from an agent that does not submit adequate proof (as required by applicable legal standards) that they have been authorized by you to act on your behalf.

REQUEST RESPONSE TIME

We strive to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt.

CALIFORNIA PRIVACY NOTICE UPDATES

Validity reserves the right to amend this California Privacy Notice at our discretion and at any time. When we make changes to this notice, we will post it on our website and update the “Effective Date” below. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

CONTACTING US

We welcome any questions, comments, or concerns you may have regarding this California Privacy Notice. Please do not hesitate to contact us as follows:

email: [email protected]

phone: 1-800-961-8205 (US toll-free)

mail: Attn: Privacy Department

Validity, Inc

100 Summer Street, Suite 2900

Boston, Massachusetts 02110

United States