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 in connection with the receipt and use of Validity’s content,communications (including emails), and services (“Offerings”) or from any of the websites operated by Validity (the “Sites”), and other services provided by us both online and offline except as otherwise set forth in a separate agreement between you and Validity.

Validity fully describes its practices related to processing Personal Information (as defined in CCPA/CPRA) 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.

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 twelve (12) months (note that the summary table below is based on CCPA enumerated categories, and only includes the categories in scope):

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

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

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 materials on our Sites and others;
• 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.

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.

Validity doesn’t sell Personal Information (including of known minors under 16 years of age) within the meaning of the CCPA/CPRA.

In certain limited circumstances, Validity may disclose Personal Information in a way that would constitute “sharing” under CCPA/CPRA such as with third-parties that Validity contracts with for purposes of cross-context behavioral advertising (as defined under the CCPA/CPRA).

You can request to opt-out of sharing your Personal Information at any time by using our cookies preference banner or by clicking the “Do not share my info” link in the footer. See more details under Opt-Out of sharing section in this policy below.

Validity does not process or share Personal Information of known minors under 16 years of age.

The CCPA and CPRA provide California residents with specific rights regarding their Personal Information. This section describes your rights as provided by CCPA/CPRA, for more information please visit this page: https://oag.ca.gov/privacy/ccpa. Please note that some of those rights may not be applicable to our processing of your Personal Information.

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 twelve (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 CCPA/CPRA.

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 with 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 (as defined under CCPA/CPRA) is used and disclosed, subject to certain exceptions as identified in CCPA/CPRA.

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

Right to Opt-out of Automated Decision-Making Technology (Profiling)

Validity combines data obtained by the methods described above to help us determine what products and services might be of interest to you and when you might be ready to make a purchase based on repeated interaction with Validity websites, emails, and content. Validity marketing and sales personnel are involved in this process and no automated decisions are made that would result in legal effects or similarly significantly affect an individual.

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.

To exercise the opt-out of all cookies that may result in a “share” of Personal Information for cross-context behavioral advertising, please see the instructions below:

• Click on the “Do not share my info“, move toggle to the left of Share of Personal Data or by selecting Reject All button for cookies you will also opt-out of Share of Personal Data.(If you visit us from a different device or browser or clear cookies, then you may need to return to this screen to re-select your preferences.) “Privacy Preference Center” can be accessed any time via an icon at the bottom left side of the Site or by clicking the “Do not share my personal info” link in the footer of the page or cookie banner (as applicable).
• Set the “Global Privacy Control” for each participating browser system that you use. For instructions on how to download and use GPC, please visit https://globalprivacycontrol.org/

Validity will decide what pieces of Personal Information to use for verification based on the information we maintain about you in our systems and the right you are exercising (where required). We will strive not to collect any additional Personal Information 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 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.

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.

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.

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.

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

Effective Date: March 2024