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“DO NOT SELL MY PERSONAL INFORMATION” Notice

 

This document is intended to explain what the “Do Not Sell My Personal Information” link on Clé Tile’s webpages means. The purpose of this article is to explain (1) why Clé Tile’s webpages contain the “Do Not Sell” link, (2) what it means to “sell” “personal information,” as those terms are defined under California law (3) that Clé Tile does not sell personal information that directly identifies you, even under the California definition of “sale,” (4) what happens if you tell Clé Tile not to “sell” your personal information, (5) how Clé Tile implements your choice to block it from “selling” your personal information, and (6) how Clé Tile maintains your “Do Not Sell” Choice.

Why Does Clé Tile Provide the “Do Not Sell” Link?

Clé Tile provides the “Do Not Sell” link to comply with the California Consumer Privacy Act (CCPA), California Civil Code Section 1798.100 et seq., effective January 1, 2020. The CCPA is a new data protection law that provides California residents with certain choices about their data, including the ability to tell companies not to “sell” their personal information. The link is there to inform you of this choice. Although the CCPA only gives California residents the right to make these requests, we allow non-California residents with the same choices about their personal information. Please see our [LINK TO PRIVACY POLICY] for more information.

 

What Does it Mean to “Sell” “Personal Information” Under the CCPA?

The CCPA broadens the definition of “sale” and “personal information” beyond how you might commonly interpret those terms. Under the CCPA, “personal information” includes information that is not necessarily directly tied to an individual’s identity but may be associated with a device. This includes identifiers such as IP addresses, web cookies, web beacons, and mobile AdIDs. In many cases, this type of information is not associated with you, but they are unique identifiers that could be. Similarly, the term “sell” is defined to include not just selling in exchange for money, but also sharing or transferring personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which is not limited to the exchange of money. Certain things are not considered “sales,” including when (1) personal information is shared with a service provider that is contractually prohibited from using the personal information for any purpose beyond the service specifically requested (“service provider exception”), or (2) when the consumer has directed a company to disclose the personal information (“consumer directed exception”).

 

Does Clé Tile “Sell” my Personal Information?

Clé Tile does not sell information that directly identifies you, like your name, address, social security number, banking information, or phone records. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information, or in the limited additional circumstances outlined in our Privacy Policy (such as where we are legally required to share the information).

However, the CCPA’s broad definitions of “sale” and “personal information” may deem the common flow of information in the digital analytics and advertising ecosystem to be a sale. Like most companies that operate commercial websites, Clé Tile utilizes online analytics to measure the ways users engage with our websites. These analytics, in turn, inform how we perform online advertising. In order to provide these analytics and facilitate online advertising, Clé Tile uses third-parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our websites/apps and on third-party websites/apps. For instance, we may request that a third-party facilitate the placement of Clé Tile ads on a particular website after a consumer has previously visited www.cletile.com. The third-parties we use for these purposes generally do this by placing a cookie on a user’s browser so it can identify that the same browser visited other websites. Similarly, where our webpages provide space for advertisements, these third-parties may use identifiers such as cookies for websites, or the device’s mobile AdID for apps, to facilitate real-time bidding by advertisers

Where we can reasonably ensure via contract that the third-parties described above can and will use a device identifier solely to provide the specific service we have requested, and will not use or share the data for other purposes, we will not deem that sharing a “sale.” In most cases, we’ve determined that our data analytics providers that measure the ways users engage with our websites and apps meet this standard and, accordingly, we will not block the sharing of an identifier with those entities even when you choose to opt-out through the “Do Not Sell” link.

 

In some cases, though, Clé Tile does not ultimately control how such identifiers are used by some third-parties (particularly in some cases in the online advertising ecosystem), and so we can’t determine that all sharing with third-parties in these cases fall within the service provider exception under the law. As a result, we are currently treating our sharing with some of these third-parties as a “sale” under the CCPA.

 

How Do I Instruct Clé Tile Not to “Sell” my Personal Information?

To formally record your preference that Clé Tile not sell your personal information, fill out the form below:

Clé Opt-out Form

You may also contact us by email at admin@cletile.com or by telephone at: (415) 887-9011 

 

What Happens When I Instruct Clé Tile not to “Sell” my Personal Information?

When a user of our website makes the “Do Not Sell” choice, we will attempt to block further sharing of the covered identifiers with the third-parties we engage on those digital properties or any other entity that does not fall within the service provider exception or the consumer directed exception.

 

How Does Clé Tile Maintain my “Do Not Sell” Choice?

For the Clé Tile website, if you do not log in to your account (or do not have an account with us) and instead set a “Do Not Sell” preference that is specific to the site that you are visiting, please be aware that the setting will only work if your browser is set to accept cookies. Likewise, if you clear your browser cookies, the cookie-based “Do Not Sell” setting will be erased, and you will need to reset the setting for that web domain.

 

If you choose to sign in and set a “Do Not Sell” setting tied to your account, we will attempt to identify and honor that setting whenever you are logged into the Clé Tile website. This persistent setting will have no effect, however, when you have not signed in to the Clé Tile website. In that case, only the setting set for a particular website, if one exists, will apply. Please note that when you set a “Do Not Sell” setting in your account, we will attempt to also set your setting for the website you are using at that time— but again, that setting may not work if your browser does not accept cookies or if you later delete cookies or delete data on your app.

 

You can check the current status of your “Do Not Sell” setting for the Clé Tile website and change that setting at any time by clicking on the link in the footer of the Clé Tile webpage you are browsing. For more information about Clé Tile privacy practices and our approach to the CCPA, please see our PRIVACY POLICY.