California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time ("CCPA").

Personal Information does not include information that is:

Lawfully made available from government records.
Deidentified or aggregated.
Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information and Sensitive Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold or shared for cross-context behavioral advertising purposes, in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category's statutory definition and may not reflect all of the specific types of Personal Information and Sensitive Personal Information associated with each category.

Category	Collected	Disclosed	Sold/Shared
A. Identifiers
Examples: Name, alias, business postal address, unique personal identifier, online identifier, internet protocol address, business or personal email address (if you provide it to us), business account name, or other similar identifiers.	Yes	Yes	No
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Examples: Name, signature, address, telephone number, passport number, employment, bank account number, credit card number, debit card number, or any other financial information.	Yes	Yes	No
C. Characteristics of Protected Classifications under California or Federal Law
Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	No	N/A	N/A
D. Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No	N/A	N/A
E. Biometric Information
Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	N/A	N/A
F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer's interaction with an internet website, application or advertisement.	Yes	Yes	No
G. Geolocation Data
Example: Precise physical location.	No	N/A	N/A
H. Sensory Information
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A	N/A
I. Professional or employment-related information
Examples: Job application or resume information, past and current job history, and job performance information.	Yes	Yes	No
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	No	N/A	N/A
K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer's preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Yes	No
L. Sensitive Personal Information (Identifiers)
Examples: A consumer's social security, driver's license, state identification card, or passport number	No	N/A	N/A
M. Sensitive Personal Information (Log-In and Financial Information)
Examples: Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.	Yes	No	No
N. Sensitive Personal Information (Precise Geolocation)Geolocation data used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet.	No	N/A	N/A
O. Sensitive Personal Information (Group Membership)
Examples: Racial or ethnic origin, religious or philosophical beliefs, or union membership.	No	N/A	N/A
P. Sensitive Personal Information (Contents of Communications)
Examples: The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication.	No	N/A	N/A
Q. Sensitive Personal Information (Genetic Data)	No	N/A	N/A
R. Sensitive Personal Information (Identifying Biometric Information)	No	N/A	N/A
S. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Health)	No	N/A	N/A
T. Sensitive Personal Information (Personal Information Collected and Analyzed Concerning a Consumer's Sex Life or Sexual Orientation)	No	N/A	N/A

Use of Personal Information

We collect your Personal Information for the following specific business and commercial purposes:

Providing Services: Providing our services.
Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
Personalization: Personalizing your experience on our services such as presenting tailored content.
Sending Messages: Sending you text messages or push notifications.
Facilitating Payments: Facilitating transactions and payments.
De-identification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.
Processing Applications: Processing your job application.
Safety Issues: Responding to trust and safety issues that may arise.
Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging: Debugging to identify and repair errors that impair existing intended functionality.
Transient Use: Short-term, transient use.
Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Research: Undertaking internal research for technological development and demonstration.
Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

Collection and Disclosure of Your Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

A. You/Your Devices: You or your devices directly.

B. Affiliates: Affiliates.

C. Resellers: Consumer data resellers.

D. Partners: Business partners.

E. Public Sources: Publicly accessible sources.

In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties for the purposes of Providing Services, Facilitating Payments, Enabling Transactions, Communicating, Sending Messages, Marketing, Auditing Interactions, Processing Applications, Compliance, Debugging, Contracting Vendors, and Product Improvement.

I. Advertisers: Advertising networks.

Personal Information we disclosed: Identifiers, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

II. Analytics Providers: Data analytics providers.

Personal Information we disclosed: Identifiers, Internet of Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

III. Social Networks: Social networks.

Personal Information we disclosed: Identifiers, Internet or Other Electronic Network Activity Information.

IV. Affiliates: Affiliates.

Personal Information we disclosed: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

V. Vendors: Vendors and service providers.

Personal Information we disclosed: Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Internet or Other Electronic Network Activity Information, Professional or employment-related information.

VI. Third Parties as Legally Required: Third parties as required by law and similar disclosures.

Personal Information we disclosed: Identifiers, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

VII. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.

Personal Information we disclosed: Identifiers, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

VIII. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

Personal Information we disclosed: Identifiers, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits our website users and customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our website user's personal information with unaffiliated third parties for their own direct marketing purposes.

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties to whom we have disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months. Click here to request access to your Personal Information.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. Click here to request deletion of your Personal Information.

Right to Correct. You may submit a verifiable request that we correct inaccurate Personal Information that we maintain about you.

Verification. Requests for access to, deletion of, or correction of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access, deletion, or correction request, please provide us with your name and phone number and we will follow up if we need additional information to verify your request.

Right to Opt Out. We do not sell or share (for cross-context behavioral advertising purposes) your Personal Information.

Right to Limit Use and Disclosure of Sensitive Personal Information. In some circumstances, you may limit our use and disclosure of your Sensitive Personal Information. We do not use or disclose your Sensitive Personal Information for purposes other than the limited purposes permitted by CCPA.

Right to No Retaliation. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations, including if you are an employee, applicant, or independent contractor of our business.

Submit Requests. To exercise your rights under the CCPA, please use the link above or email us at info@whotechs.com.

Authorizing an Agent: To authorize an agent to make a request to know, delete, correct, or opt out on behalf of a California resident, please send a written authorization signed by the resident to info@whotechs.com.

Minors

We do not knowingly sell or share (for cross-context behavioral advertising purposes) the Personal Information of minors under 16 years of age.

However, since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove Personal Information and Sensitive Personal Information provided by you or publicly posted by you, by accessing your company account through https://suite.whotechs.com/ or another product or service as applicable and editing/removing your Information. You will need your password to access the company account. You may also send us an email asking us to remove certain posted content at privacy@whotechs.com. In the alternative, you may write to us: Who Analytics Dijital Hizmetler Ltd. Şti., Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye, Attn: Privacy Team/Privacy Policy.

We will be happy to review, update, or remove Information and/or content as appropriate. Residual copies of Personal Information, Sensitive Personal Information, and/or content that have been removed from your account and/or the websites and online services may remain in our backup systems for approximately one month. We may still retain your Personal Information and Sensitive Information, if at all and if necessary, to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, please email us at info@whotechs.com or write to us at Who Analytics Dijital Hizmetler Ltd. Şti., Vişnezade Mah. Süleyman Seba Cad. No:79/1 Beşiktaş, Istanbul, Türkiye.

Last Updated: January 16, 2024