Last updated: March 2020
When you use California Living Trusts (“we,” or “us”) services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
1. Information We Collect
A. Information You Provide.
We may collect information you provide directly via the Services. We may ask you for some or all of the following types of information when you register with our Services, access various content or features, register for contests or sweepstakes, submit comments and other content, order products, or directly contact us with questions or feedback:
• Contact information, such as name, e-mail address, postal address, and telephone number;
• User name, display name, and password;
• Demographic information, such as age information and gender;
• Payment information, such as credit card number and expiration date;
• Communications preferences;
• Search queries;
• Stories, comments, photos, and other information posted in our interactive online features;
• Correspondence and other information that you send to us; and
• Additional information as otherwise described to you at the point of collection or pursuant to your consent.
B. Information Automatically Collected.
We also may collect certain information automatically when you visit the Services (“Usage Information”), including:
• Your browser type and operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Geolocation information;
• Other unique identifiers, including mobile device identification numbers;
• Sites or mobile apps you used before and after using the Services;
• Pages you view and links you click on within the Services;
• Information collected through cookies, web beacons, and other technologies;
• Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and
• Standard Server Log Information.
o Cookies, Pixel Tags, and Local Shared Objects
Cookies are small bits of information that are stored by your computer’s web browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services.
Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.
Local Shared Objects (sometimes referred to as “Flash Cookies”) are similar to standard cookies except that they can be larger and are downloaded to a computer or mobile device by the Adobe Flash media player. Please note that you may need to take additional steps beyond changing your browser settings to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.
o Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Services and deleted or deactivated thereafter.
o Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
o Device Fingerprinting
o In-App Tracking Methods
There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.
For further information on tracking technologies and your choices regarding them, please see Section 6 below.
C. Information from Other Sources.
2. Use of Information
We may use information that we collect through the Services for a variety of purposes, including to:
• Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
• Contact you via email and otherwise about products, services, and events that we think might be of interest to you;
• Contact you with surveys, legal notices, and other information that may be relevant to your use of the Services;
• Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
• Publish stories, comments, and other information posted in our interactive online features;
• Process employment applications and inquiries;
• Create articles and other content;
• Detect, investigate, and prevent activities that may violate our policies or may be fraudulent or illegal;
• Deliver advertising, including interest-based advertising, to show you relevant ads both on our Services and elsewhere, and measure the effectiveness and reach of ads; and
• As otherwise described to you at the point of collection or pursuant to your consent.
3. Sharing of Information
We want you to understand when and with whom we may share the information we collect. We may share information that we collect through the Services with third parties as follows:
• Corporate Parents, Affiliates, and Subsidiaries. We may share your information with our corporate parents, subsidiaries, and other affiliated entities for a variety of purposes, including business, operational, and marketing purposes.
• Service Providers. We may share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host the Services, manage databases, host a store or other e-commerce platform, perform analyses, conduct surveys, place California Living Trusts -branded content on third-party websites, or send communications and newsletters for us.
• Select Business Partners. We may share your information with select business partners so that they can provide you with special offers, promotional materials, advertisements and other materials that may be of interest to you. However, California Living Trusts is not responsible for the privacy practices of these business partners, which may use your information for their own purposes.
• Other Parties When Required By Law or as Necessary to Protect the Services. We may disclose your information to third parties in order to protect the legal rights, safety, and security of California Living Trusts, our corporate parents, affiliates, and subsidiaries, and the users of our Services; enforce our Terms of Service; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
• In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
• Other Parties With Your Consent. We may share information about you with third parties when you consent to such sharing, including when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool.
• Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.
4. Social Networking Services
California Living Trusts has worked with certain third-party social media providers to offer you their social networking services through our Services. For example, you can use third-party social networking services, including but not limited to Facebook, Twitter, and others to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.
5. Links to Third Party Sites and Services
6. Analytics and Advertising Tracking Technologies.
You may choose whether to receive interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. You can also opt out of interest-based advertising within mobile apps based on advertising identifiers on your device (for example, through cross-app tracking). See the Advertising and Privacy options under your device’s Settings for more information. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). California Living Trusts is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, California Living Trusts currently does not take action in response to these signals.
7. Communications Preferences
You may choose to receive promotional communications (including emails and text messages), newsletters, and similar communications from us. You may opt out of receiving certain promotional communications from us at any time by (i) for promotional emails, by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive; and (ii) for text messages, following the instructions provided in text messages from us to text the word “STOP”). Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. Opt-out requests for e-mail may take up to 10 business days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature.
8. Your California Privacy Rights
Pursuant to California’s “Shine The Light” law, California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. You may request this disclosure information at California Living Trusts and indicate in the email subject line “California Shine The Light Request” so that we can process your request. Please include your mailing address, state of residence and email address with your request.
9. Children’s Privacy
The Services do not knowingly collect, use, or disclose personal information from children under the age of 13 without prior parental consent, except as permitted by the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and believe we have collected information in a manner not permitted by COPPA, please contact us at https://californialivingtrusts.com/contact/
10. Data Security
We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us. Please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Services using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.
11. International Users
Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.
If you are a resident of the EEA or Switzerland, the following information applies:
Purposes of processing and legal basis for processing
As explained above, we process personal data as defined under data protection laws in various ways depending upon your use of the Services. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interest in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.
Right to lodge a complaint
Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Upon the start of enforcement of the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.
If you are a resident of the EEA or Switzerland, you are entitled to the following rights, which may be exercised by contacting us as described below. In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.
• The right to request data erasure. You have the right to have your data erased from our website if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
13. Contact Us
CALIFORNIA LIVING TRUSTS
3838 Camino Del Rio North
San Diego, CA 92108
For more information about our third party partners, including information on how to opt out of data collection, please visit https://www.caprivacy.org/opt-out