Privacy Policy CCPA

EFFECTIVE DATE: June 8, 2021

This Privacy Notice for California Residents (this “Notice”) is part of the Papathemes Privacy Policy and applies, in addition to the terms in the Privacy Policy, solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in compliance with the California Consumer Privacy Act of 2018 (CCPA). PLEASE READ THE PRIVACY POLICY IN ADDITION TO THIS NOTICE. Terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our Website collects Personal Information, further defined in Section 3 of the Privacy Policy. For purposes of this Notice, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.

Our website has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category	Specific Fields
A. Identifiers.	First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the Data Subjects.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the consumers. Note: Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	None.
D. Commercial information.	Purchased product/service.
E. Biometric information.	None.
F. Internet or other similar network activity.	IP Address. Papathemes also collects the activity of the consumer on the onsite widget, to provide this data later on to IPP, to indicate if the user read or navigated the UGC onsite widget prior to making the order, so IPP will know that this order can be contributed to the UGC as displayed on the site.
G. Geolocation data.	Extracted from IP Address.
H. Sensory data.	None.
I. Professional or employment-related information.	None.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	None.
K. Inferences drawn from other personal information.	None.

For purposes of this Notice, “Personal Information” does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the Personal Information listed above from directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms.) For more information about how we collect your Personal Information, see Section 6 of the Privacy Policy.

Use of Personal Information

We may use or disclose the Personal Information we collect for the business purposes set forth in Section 7 of the Privacy Policy.

Sharing Personal Information

Papathemes does not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in Section 8 of our Privacy Policy.

California Residents’ Individual Rights

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Papathemes delete your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user generated content such as product reviews), or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise a right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm 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 the request.

Response Timing and Format

We try 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.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at 400 Lafayette Street, New York, NY 10003 or contact@papathemes.com. You are also welcome to contact our data protection officer at privacy@Papathemes.com.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our website, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.

Privacy Policy CCPA

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