Additional disclosures for U.S. residents, other than California Residents
If you are a U.S. resident from whom we collect Personal Data as a controller, you may have certain rights under an applicable U.S. state privacy law. You may rely on the disclosures in this Privacy Notice regarding how we collect, use, and disclose your personal information as well as the choices you can make related to your personal information.
Your Rights and Choices
In addition to the rights identified in Section 4 (“Your Rights and Choices”) above, you may have the right to opt out of the processing of the personal information for purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you and the right to appeal a decision we make with respect to your privacy rights.
You (or, where permitted by law, your authorized agent) can exercise your rights by submitting a request as described in Section G (“Authorizing an Agent”) of the Additional Disclosures for California Residents below.
Please refer to Section G of the Additional Disclosures for California Residents above for more information on exercises these rights.
Additional Disclosures for California residents
If you are a California resident from whom we collect Personal Information as a business under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), you may rely on this Privacy Notice and the additional information below.
If you are a job applicant who is a California resident, please refer to our Applicant Privacy Notice here for further information.
For the purpose of this section for California residents, “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 CCPA. Personal Information does not include information that is publicly available, deidentified, or aggregated (as those terms are defined in the CCPA) or otherwise excluded from the scope of the CCPA.
- Categories of Personal Information about you that we Collect and Disclose. The following is a list of categories of Personal Information (as defined by the CCPA) we have collected and disclosed for a business purpose.
- Identifiers. Examples: Personal and/or business contact information (e.g., name, postal address, telephone number, job title), online identifier, device identifier(s), internet protocol address, email address, account name, authentication information, and similar identifiers. We may collect this information about other people if you give us their information. We may also associate information that you submit to us, such as articles, comments, or content on our social media pages, with your identifiers.
- Categories of Personal Information in Cal. Civ. Code Section 1798.80(e). Examples: Name, address, telephone number, email address, and IP address.
- Characteristics of Protected Classifications under California or Federal Law. Examples: Gender and age range.
- Commercial Information. Examples: Information we create or retain that are fundamental to our business, e.g. records of personal property; transaction information, such as date and time of transaction, or a transaction ID provided by a customer, the merchant’s name and location product and service information, such as product version, registration and payment information, and program-specific information, when you request products or services directly from us, or participate in marketing programs; preferences that we infer about you based on products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric Information. Examples: Behavioral characteristics, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as keystroke timing, device accelerometer, scroll position, and mouse location.
- Internet or Other Electronic Network Activity Information. Examples: Cookie and web beacon data, IP address, browser type, operating system, mobile device identifier, referring URLs, pages viewed and actions you take on our online properties and apps, and behavioral-based data or biometric information, such as keystroke timing, device accelerometer, scroll position, and mouse location.
- Geolocation Data. Example: Your city, state or country or your IP address.
- Sensory Information. Examples: Photographs, audio recordings (including call recordings for customer service purposes), and video recordings.
- Professional or Employment-Related Information. Examples: Professional information such as job title, department, and name of organization. Additionally, information you provide as part of your job application or in the course of your employment with Ekata and/or Mastercard, e.g., contact information and employment history. Please see Applicant Privacy Notice for further information.
- Inferences Drawn from Personal Information. Examples: Personal characteristics, life habits, consumption habits, and interests.
- Sensitive Personal Information. Examples: Biometric information, as described in more detail above in E, for fraud and security prevention. (We note, however, that we do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit our collection and processing of this data under the CCPA).
- Sources of Collection of Personal Information. We have collected Personal Information from the following categories of sources:
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
- You/Your Devices: You or your devices directly.
- Affiliates.
- Analytics Providers.
- Users: Other users of our services.
- ISPs: Internet service providers.
- Government: Government entities.
- Advertising Networks.
- Social Networks.
- OS/Platform Provider: Operating systems and platforms.
- Partners: Business partners.
- Public: Publicly accessible sources.
- Use of your Personal Information. We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
- Providing Services: Providing our services.
- Communicating: Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing customer support.
- Connecting Third Party Services: Facilitating the connection of third-party services or applications.
- Business Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you. You may opt-out of these at any time. We do not use Customer Data for marketing purposes.
- Personalization: Personalizing your experience on our services, such as presenting tailored content.
- Sending Messages: Sending you personalized text messages as requested on our Talent Community. Please see Talent Community Privacy Notice for further information.
- Facilitating Payments: Facilitating transactions and payments.
- Job 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 Use 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 your interaction with our services 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 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 vendors and 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 advertising or marketing services, providing analytics services, or providing similar services on behalf of Mastercard’s clients.
- Research: Undertaking internal research for technological development and demonstration.
- Improving Our Services: 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.
- Disclosure of your Personal Information to Third Parties
With respect to the categories of Personal Information identified above in Section 1, we disclose your Personal Information to the following categories of third parties:
- Advertising Providers: Advertising technology companies, such as advertising networks. We disclose your Personal Information to Advertising Providers only with your consent. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data. We do not disclose Customer Data for advertising purposes.
- Analytics Providers. Companies that help us analyze and improve our online properties. We disclose your Personal Information to Analytics Providers only at your direction and only with your consent. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data.
- OS/Platform Providers: Operating systems and platforms. Personal Information we share: Identifiers; Internet or Other Electronic Network Activity Information; Geolocation Data.
- Resellers: Consumer data brokers. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Geolocation Data; Inferences Drawn from Personal Information.
- Affiliates. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
- Vendors: Vendors and service providers. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
- Integrated Third Parties: Third parties integrated into our services. Personal Information we disclose: Identifiers; Internet or Other Electronic Network Activity; Geolocation Data.
- Third Parties as Legally Required: Third parties as required by law and similar disclosures. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
- Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer. Personal Information we disclose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Inferences Drawn from Personal Information.
- Third Parties with Consent or Direction: Other third parties for whom we have obtained your direction or permission to disclose your Personal Information. Personal Information we may disclose: Identifiers; Commercial Information
We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.
- Collection and Sale of your Personal Information to Other Parties
We sell your Personal Information. However, we only sell your Personal Information for fraud prevention and identity verification purposes, as detailed further below.
With respect to Personal Information that we sell, we have collected information from Resellers (consumer data brokers).
We do not “share” Personal Information with third parties for “cross-context behavioral advertising” (“CCBA”).
The following is a list of categories of Personal Information (as defined by the CCPA) we have sold.
- Identifiers. Examples: Personal and business contact information (e.g., name, postal address, telephone number), internet protocol address, and email address. We may collect this information about other people if you give us their information.
- Categories of Personal Information in Cal. Civ. Code Section 1798.80(e). Examples: Name, postal address(es), telephone number, email address, and IP address.
- Characteristics of Protected Classifications under California or Federal Law. Examples: Age range, e.g., 35-39 years of age.
- Geolocation Data. Example: Your city, state or country, or your IP address.
- Associated People. Example: Household members, i.e., people with the same current address.
- Contact Information Metadata. Examples: Mobile phone carrier name, mobile phone carrier line type, mobile phone number subscriber name, and email address registered owner name.
- Device Information. Examples: Browser, ISP carrier, and platform.
With respect to the categories of Personal Information identified above, we have sold Personal Information to our Customers, who use our identity verification and fraud prevention products. We share the following categories of Personal Information to our Customers for this purpose: Identifiers; Categories of Personal Information in Cal. Civ. Code Section 1798.80(e); Characteristics of Protected Classifications under California or Federal Law; Internet or Other Electronic Network Activity Information; and Geolocation Data.
We do not have actual knowledge that we sell Personal Information of consumers under 16 years of age or that we share Personal Information of consumers under 16 years of age for CCBA.
- Retention
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
- Your Privacy Rights
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, shared with third parties for CCPA, or disclosed by us; (2) purposes for which categories of Personal Information are collected, sold, or shared with third parties for CCBA by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed Personal Information; and (5) specific pieces of Personal Information we have collected about you.
- 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. We maintain a record of such request as required by the CCPA.
- Right to Correct. You have the right to correct inaccurate Personal Information that we maintain about you.
- Verification. Requests for access to or deletion 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 or deletion request, please provide us with your email address, name, phone number, and address.
Right to Opt Out. In some circumstances, you may opt out of the sale of Personal Information.
- Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your rights, except where the different price or level of quality of good or service is reasonably related to the value of the data that we receive from you.
Submit Requests. To exercise your rights under the CCPA email us at privacysupport@ekata.com or call our toll-free number: +1 (855) 927-1072.
Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, correct, or opt out on behalf of a California resident, email us at privacysupport@ekata.com or call our toll-free number: +1 (855) 927-1072. Please note that we will require you to attach a written authorization signed by the resident whose Personal Information will be subject to the request.
- CCPA Metrics
The following metrics are based on requests received from “consumers” as the term is defined by the CCPA.
|
|
Demandes reçues
|
Demandes satisfaites en totalité ou en partie
|
Demandes refusées
|
Durée médiane en jours pour répondre
|
Durée moyenne en jours pour répondre”
|
|
|
26469
|
23081
|
3388
|
36
|
35.9
|
|
|
9
|
2
|
7
|
36
|
33.3
|
Demandes de prise de connaissance
|
0
|
0
|
0
|
0
|
0
|
Demandes de retrait de la vente
|
93
|
76
|
17
|
10
|
12.6
|
Demandes de limitation de l’utilisation des données
|
0
|
0
|
0
|
0
|
0
|
