CCPA Privacy Notice
Effective November 21, 2022
Privacy Policy Addendum for Residents of California
Your Rights and Choices
The California Consumer Privacy Act of 2018 ("CCPA") provides consumers residing in California with specific rights regarding their personal information. This Notice supplements the Chowly Privacy Policy and applies solely to California Consumers.
Personally Identifiable Information ("personal information") is defined as information that identifies, relates to, describes, or could reasonably be linked to you as an individual.
Exclusions from Personal Information
Personal information does NOT include:
- Publicly available information from government records
- De-identified or aggregated consumer information
- Health or medical information covered by HIPAA and CMIA or clinical trial data
- Personal information covered by sector-specific privacy laws (FCRA, GLBA, FIPA, DPPA)
Collecting of Personal Information
Chowly has collected the following categories within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Real name, postal address, email, IP address, SSN, driver's license number, passport number | YES |
| B. California Customer Records | Name, signature, SSN, physical characteristics, address, phone, passport, driver's license, insurance policy, financial/medical information | YES |
| C. Protected Classifications | Age, race, color, ancestry, national origin, religion, marital status, disability, sex, sexual orientation, veteran status, genetic information | NO |
| D. Commercial Information | Records of products/services purchased, obtaining histories, consuming tendencies | YES |
| E. Biometric Information | Fingerprints, faceprints, voiceprints, iris/retina scans, keystroke patterns, gait, health/exercise data | NO |
| F. Internet/Network Activity | Browsing history, search history, website/application interactions, advertisement interactions | YES |
| G. Geolocation Data | Physical location or movements | NO |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory information | NO |
| I. Professional/Employment Information | Job history, performance evaluations | NO |
| J. Education Information | Grades, transcripts, class lists, student identification, financial information, disciplinary records | NO |
| K. Inferences | Profile reflecting preferences, characteristics, psychological trends, behavior, attitudes, abilities, aptitudes | NO |
Sources of Personal Information
Chowly obtains personal information from:
- Direct collection when you complete forms or purchase services
- Indirect collection through website browsing
Use of Personal Information
Chowly may disclose personal information for business purposes as described in the Privacy Policy.
Sharing of Personal Information
Disclosures for Business Purpose
In the preceding twelve (12) months, Chowly has disclosed these categories for business purposes:
- Category A: Identifiers
- Category B: California Customer Records personal information categories
- Category D: Commercial information
- Category F: Internet or other similar network activity
When disclosing personal information for business purposes, Chowly enters contracts requiring recipients to keep information confidential and use it only for performing the contract.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold any of your personal information unless a transfer of this information to an advisor, broker or third-party insurance marketer was authorized by you.
Chowly does not collect or share personal information of any covered consumers under age 16.
Access to Specific Information and Data Portability Rights
Subject to CCPA exceptions, you have the right to request disclosure of:
- The categories of personal information collected about you
- The categories of sources for that personal information
- Chowly's business or commercial purpose for collecting or selling your information
- The categories of third parties with whom personal information is shared
- The specific pieces of personal information collected about you
Contact: [email protected]
Deletion Request Rights
Subject to CCPA exceptions, you may request deletion of your personal information collected and retained by Chowly. Upon confirming a verifiable consumer request, Chowly will delete (and direct service providers to delete) your personal information unless an exception applies.
Exceptions to Deletion
Chowly may deny deletion requests if retaining information is necessary to:
- Complete transactions, provide requested goods/services, or perform contract obligations
- Detect security incidents, protect against malicious/fraudulent/illegal activity
- Debug products to identify and repair errors
- Exercise free speech or ensure another's free speech rights
- Comply with California Electronic Communications Privacy Act
- Engage in public or peer-reviewed scientific, historical, or statistical research
- Enable internal uses reasonably aligned with consumer expectations
- Comply with legal obligations
Contact: [email protected]
Exercising Access, Data Portability, and Deletion Rights
Only you, a person registered with the California Secretary of State acting as your authorized agent, or an authorized representative on behalf of your minor child may make a verifiable consumer request. You may make a request for access or data portability twice within a 12-month period.
Response Timing and Format
Chowly endeavors to respond to verifiable consumer requests within forty-five (45) days of receipt. If more time is required (up to 90 days), Chowly will inform you of the reason and extension period in writing.
Chowly does not charge fees to process or respond to verifiable consumer requests unless excessive, repetitive, or manifestly unfounded.
Non-Discrimination
Chowly will not discriminate against you for exercising CCPA rights. Specifically, Chowly will not:
- Deny you goods or services
- Charge different prices or rates for goods or services
- Provide different level or quality of goods or services
- Suggest you may receive different pricing or quality
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section 1798.83) permits California residents to request information about disclosure of personal information to third parties for direct marketing purposes.
Contact Information
For questions about this California privacy notice, collection and use of information, or your choices and rights:
Email: [email protected]
Mailing Address:
Chowly, Inc.
225 W. Wacker Drive, Suite #550
Chicago, IL 60606