This California Privacy Policy describes how U&I Digital LLC and its subsidiaries, affiliates, and related entities (collectively, the "Company," "we," or "us") collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act ("CCPA") requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.
This Privacy Policy does not apply to our collection and use of personal information in an employment capacity. This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy policy at: [GENERAL PRIVACY POLICY URL].We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:
The chart below identifies the categories of personal information we collected from our consumers within the last 12 months and the expected retention period.
| Category | Examples | Collected | Retention Period |
|---|---|---|---|
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | Yes | Perpetual |
| B. California Customer Records | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes | Perpetual |
| C. Protected Classes | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information). | Yes | Perpetual |
| D. Commercial Information | Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Perpetual |
| E. Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Yes | Perpetual |
| F. Internet Activity | Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites. | Yes | Perpetual |
| G. Geolocation Data | Physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited. | Yes | Perpetual |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes | Perpetual |
| I. Professional Information | Current or past job history or performance evaluations. | Yes | Perpetual |
| J. Inferences | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes | Perpetual |
| K. Sensitive Personal Information | Further identified in the chart below. | Yes | Perpetual |
Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.
| Sensitive Personal Information Category |
|---|
| L.1. Government identifiers, such as your Social Security number (SSN), driver's license, state identification card, or passport number. |
| L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password. |
| L.3. Precise geolocation, such as GPS data from a consumer's mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet. |
| L.4. Racial or ethnic origin. |
| L.5. Citizenship or immigration status. |
| L.6. Religious or philosophical beliefs. |
| L.7. Union membership. |
| L.8. Mail, email, or text messages not directed to the Company. |
| L.9. Genetic data. |
| L.10. Neural Data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information. |
| L.11. Unique identifying biometric information. |
| L.12. Health information. |
| L.13. Sex life or sexual orientation information. |
| L.14. Children's personal information (under age 16). |
We obtain the categories of personal information listed above from the following categories of sources:
We may use and disclose the personal information, including, without limitation, sensitive personal information, we collect to advance the Company's business and commercial purposes, specifically to:
We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):
We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.
The VaDi platform utilizes certain third party tools and platforms, including without limitation, OpenAi and Deepgram. Information that you provide to the VaDi platform is shared with OPenAi and Deepgram to process your information, as contemplated by the VaDi platform. Any such information is subject to the privacy policies and terms of use of these third party providers. You should carefully review their license terms and conditions and privacy policies prior to use of our VaDi platform (and from time to time, as their practice may change from time to time). In general, these third party providers will process personal and sensitive information you provide to them to fulfill the purpose for which you are using such information on the VaDi platform. In general, you retain all rights in and to the data you provide and have the right to utilize any outputs from the use of these third-party services. In general, the third party provide has the right to utilize any aggregated data to train their artificial intelligence, but does not have the right to utilize any personal data you provide to them for purposes other than to fulfill your uses on the VaDi platform. Again, we urge you to review carefully the terms and conditions applicable to use of OpenAi and Deegram, as all such uses will be subject to those terms and conditions.
We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA's other contract requirements for engaging service providers or contractors.
We do not sell your personal information to third parties.
you are a California resident, the CCPA grants you the following rights regarding your personal information:
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you:
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it.
You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.
You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right
You have the right to request that businesses stop selling or sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in").
As we do not sell or share consumers' personal data, we do not currently provide these consumer rights.
When a business uses automated decision-making technology (ADMT) to make significant decisions about you, you may have rights to:
ADMTs are technologies that process personal information and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision.
We do not currently use ADMT to make significant decisions about consumers, so we do not provide ADMT access, opt-out, or appeal rights.
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.
We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our website to review the current Privacy Policy in effect.
If you have any questions or comments about this policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address: 3 Rosewood Ln, Suite 105 Denville, NJ 07834 USA