(last revised August 24, 2021)
sticky.io collects 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, household, or device (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in California law. This Notice provides you with information on how sticky.io collects, uses, and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights.
As a company that conducts activities that are financial in nature, sticky.io is a “financial institution” as that term is defined in the Gramm-Leach-Bliley Act (“GLBA”). While the California law does not exempt financial institutions like sticky.io, from its requirements, it does exempt personal information collected by a financial institution pursuant to the GLBA. Accordingly, much, if not all, of the data consumers provide to sticky.io, or that we collect from our merchant clients regarding their consumers, will fall within the GLBA exemption.
sticky.io recognizes the eleven (11) broad categories of personal information referenced in California law that a business may collect about a consumer. In particular, sticky.io has collected the following categories of personal information from consumers within the last twelve (12) months.
Personal information does not include:
Any data that falls under one of the bullet points above will not be considered “personal information” under California law.
We have obtained the categories of personal information listed above from the following categories of sources:
sticky.io may use this information to:
sticky.io will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing notice to you. Such notice may be delivered, for example, by posting an updated California Privacy Notice.
sticky.io may disclose your personal information to a third party for business purposes. When we do so, sticky.io enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract.
Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company’s privacy practices.
We share your personal information with the following categories of third parties for a business purpose:
California law requires sticky.io to provide you with a statement on its personal information disclosures for a business purpose that reference the eleven (11) categories of information reflected in the chart above. In the preceding twelve (12) months, sticky.io has disclosed the following categories of personal information for a business purpose:
In the preceding 12 months, we have not sold the personal information of consumers.
Access & Data Portability Rights
You have the right to request that sticky.io disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:
Deletion Request Rights
Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.
California law provides a number a reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to sticky.io by:
Eligibility and Verification of Requests
Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
sticky.io endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If sticky.io requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.
If you have an online account with us, we will deliver our written response to your online account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request or have denied a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
sticky.io will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by California law, sticky.io will not:
How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?
We currently recognize and adhere to automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit sticky.io?
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.