CCPA Privacy Notice Addendum 2023 (CCPA)

Version: 1.1.2023‍

AnyRoad Privacy Policy Addendum for California Residents

Effective Date: January 1, 2023‍

1. Introduction‍

‍This Privacy Policy Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in AnyRoad’s Privacy Policy and describes our collection and use of Personal Information. This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Note that this California Privacy Addendum does not apply to employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.

Where noted, this California Privacy Addendum also does not apply to personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”). Unless otherwise noted, this exemption will expire on January 1, 2023.‍

2. Information We Collect About You and How We Collect It‍

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect, and over the prior twelve (12) months have collected, the following categories of personal information from our consumers:

Personal information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.‍

3. Sources of Personal Information‍

We collect personal information about you from the sources described in our Privacy Policy.‍

4. How We Use Your Information‍

‍We may use, “sell” for monetary or other valuable consideration, or disclose the personal information we collect and, over the prior twelve (12) months, have used, “sold” for monetary or other valuable consideration, or disclosed the personal information we have collected, for the purposes described in our Privacy Policy as well as the following additional purposes.

Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

Performing services on behalf of our business partners, including providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of our business partners.

AnyRoad will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.‍

5. To Whom Do We Share Your Personal Information‍

‍AnyRoad may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.‍

Disclosures of Personal Information for a Business Purpose‍

In the preceding twelve (12) months, AnyRoad has disclosed the following categories of personal information for a business purpose to the listed categories of third parties:‍

A. Identifiers:‍

Categories of Third Parties: Service Providers, Business partners, and Internet cookie information recipients, such as analytics and behavioral advertising services.‍

B. California Customer Records personal information categories:‍

Categories of Third Parties: Service Providers and Business partners.‍

C. Protected classification characteristics under California or federal law:

‍Categories of Third Parties: Service Providers and Business partners.‍

D. Commercial information:

‍Categories of Third Parties: Service Providers and Business partners.‍

F. Internet or other similar network activity:

‍Categories of Third Parties: Service Providers, Business partners, and Internet cookie information recipients, such as analytics and behavioral advertising services.‍

G. Inferences drawn from other personal information:

‍Categories of Third Parties: Service Providers and Business partners.‍

6. To Whom Do We Sell Your Personal Information‍

‍As noted in our general Privacy Policy, we do not sell your personal information as the term “sell” is commonly understood to require an exchange for money.

However, the California State Attorney General may issue guidance on whether the use of advertising and analytics cookies on our Website may be considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA to include both monetary and other valuable consideration. Until such guidance has been issued and in order to be as transparent as possible with users of our Website, we continue to consider it a “sale” and will comply with the restrictions of the “sale” of this information to the extent technologically feasible. This “sale” would be limited to our use of third-party analytics cookies and their use in understanding how people use and interact with our Services.

In the preceding twelve (12) months, AnyRoad has “sold” the following categories of personal information to the following categories of third parties for monetary or other valuable consideration:‍

A. Identifiers:

‍Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services‍

B. Internet or other similar network activity:‍

Categories of Third Parties: Internet cookie information recipients, such as analytics and behavioral advertising services‍

7. Your Rights and Choices‍

‍The CCPA provides California residents (“consumers”) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your authorized agent.‍

Right to Know. You have the right to request that AnyRoad disclose certain information to you about our collection and use of your personal information over the past 12 months (a “Right to Know” request). This includes the categories of personal information we have collected about you and the categories of sources from which that personal information came from, our purpose for collecting this personal information, the categories of third parties with whom we have shared your personal information and if we have sold or disclosed your personal information, a separate list of categories of people that we disclosed and sold it to. You must specifically describe if you are making a Right to Know request or a request for the specific pieces of personal information. If you would like both the information about our collection and use over the past twelve (12) months and a copy of the specific pieces of Personal Data, you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request.‍

Access to Specific Pieces of Information (Data Portability). You also have the right to request that AnyRoad provide you with a copy of the specific pieces of personal information that we have collected or created about you (a “Data Portability” request). If you make a request for the specific pieces of personal information electronically, we will provide you with a copy of your personal information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the personal information to another third-party. You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like both the information about our collection and use over the past twelve (12) months and a copy of the specific pieces of your personal information, you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request.‍

Right to Correction. You also have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.‍

The Right to Opt-Out of Sales or Sharing of Personal Data.

‍You have right to direct AnyRoad not to “sell” your personal data to third parties for monetary or other valuable consideration, or “share” your personal data to third parties for cross-context behavioral advertising purposes and targeted advertising purposes.‍

Deletion. You have the right to request that AnyRoad delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Some exceptions to your right to delete include if we are required to retain your personal information to complete the transaction or provide you the goods and services for which we collected the personal information, or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your personal information in order to make other internal and lawful uses of it that are compatible with the context in which we collected it.‍

Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.‍

Exercising Access, Data Portability, and Deletion Rights

‍To exercise the right to know, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@anyroad.com‍

Visiting https://app.anyroad.com/ccpa‍

If you (or your authorized agent) submit a request to delete your information online, we will use a two-step process in order to confirm that you want your personal information deleted. This process may include verifying your request through your email address on record. If you fail to make your submission in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above, or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or your agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, see Authorized Agents below. We may request additional information so we may confirm a request to delete 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:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.‍

Authorized Agents

‍You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized to exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

You do not need to create an account with us to exercise your opt-out rights. You may be required to provide us with additional contact information so that we may verify your request to opt-in to the sale of your personal information. We will only use personal information provided in an opt-out request to review and comply with the request.‍

8. Changes to This CCPA Privacy Addendum‍

AnyRoad reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.‍

9. Contact Information‍

‍If you have any questions or comments about this California Privacy Addendum, the ways in which AnyRoad collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:‍

Email: privacy@anyroad.com

Postal Address: AnyRoad
505 Howard Street
4th Floor
San Francisco, CA 94105