Tula California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, 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 California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

Lawfully made available from government records.
Deidentified or aggregated.
Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category	We Collect	We Disclose	We Sell	Categories of Third Parties with Whom We Share Personal Information
A. Identifiers Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.	Yes	Yes	No	All
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Example: Name.	Yes	Yes	No	IV, VI, VII, VIII
C. Characteristics of Protected Classifications under California or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	No	N/A	N/A	N/A
D.Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes	No	All
E. Biometric Information Examples:Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	N/A	N/A	N/A
F. Internet or Other Electronic Network Activity Information Examples:Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.	Yes	Yes	No	All
G. Geolocation Data Example:Precise physical location.	No	N/A	N/A	N/A
H. Sensory Information Examples:Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A	N/A	N/A
I. Professional or employment-related information Examples: If you apply for a job with us, job application or resume information, past and current job history, and job performance information.	Yes	Yes	No	V, VI, VII, VIII
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples:Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	No	N/A	N/A	N/A
K. Inferences Drawn from Personal Information Examples:Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Yes	No	II, III, IV, V, VI, VII, VIII

Category	Information
A. Identifiers Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information All
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) Example: Name.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information IV, VI, VII, VIII
C. Characteristics of Protected Classifications under California or Federal Law Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.	We Collect No We Disclose N/A We Sell N/A Categories of Third Parties with Whom We Share Personal Information N/A
D.Commercial Information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information All
E. Biometric Information Examples:Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	We Collect No We Disclose N/A We Sell N/A Categories of Third Parties with Whom We Share Personal Information N/A
F. Internet or Other Electronic Network Activity Information Examples:Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information All
G. Geolocation Data Example:Precise physical location.	We Collect No We Disclose N/A We Sell N/A Categories of Third Parties with Whom We Share Personal Information N/A
H. Sensory Information Examples:Audio, electronic, visual, thermal, olfactory, or similar information.	We Collect No We Disclose N/A We Sell N/A Categories of Third Parties with Whom We Share Personal Information N/A
I. Professional or employment-related information Examples: If you apply for a job with us, job application or resume information, past and current job history, and job performance information.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information V, VI, VII, VIII
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) Examples:Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.	We Collect No We Disclose N/A We Sell N/A Categories of Third Parties with Whom We Share Personal Information N/A
K. Inferences Drawn from Personal Information Examples:Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	We Collect Yes We Disclose Yes We Sell No Categories of Third Parties with Whom We Share Personal Information II, III, IV, V, VI, VII, VIII

Category

Information

A. Identifiers

Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
All

B. Categories of Personal Information in Cal. Civ. Code Section
1798.80(e)
Example: Name.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
IV, VI, VII, VIII

C. Characteristics of Protected Classifications under California or Federal Law

Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

We Collect
No

We Disclose
N/A

We Sell
N/A

Categories of Third Parties with Whom We Share Personal Information
N/A

D.Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
All

E. Biometric Information

Examples:Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

We Collect
No

We Disclose
N/A

We Sell
N/A

Categories of Third Parties with Whom We Share Personal Information
N/A

F. Internet or Other Electronic Network Activity Information

Examples:Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
All

G. Geolocation Data
Example:Precise physical location.

We Collect
No

We Disclose
N/A

We Sell
N/A

Categories of Third Parties with Whom We Share Personal Information
N/A

H. Sensory Information
Examples:Audio, electronic, visual, thermal, olfactory, or similar information.

We Collect
No

We Disclose
N/A

We Sell
N/A

Categories of Third Parties with Whom We Share Personal Information
N/A

I. Professional or employment-related information
Examples: If you apply for a job with us, job application or resume information, past and current job history, and job performance information.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
V, VI, VII, VIII

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g;
34 C.F.R. Part 99)
Examples:Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.

We Collect
No

We Disclose
N/A

We Sell
N/A

Categories of Third Parties with Whom We Share Personal Information
N/A

K. Inferences Drawn from Personal Information
Examples:Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We Collect
Yes

We Disclose
Yes

We Sell
No

Categories of Third Parties with Whom We Share Personal Information
II, III, IV, V, VI, VII, VIII

[In the preceding twelve months, we have not sold any California resident’s Personal Information. We will not sell any California resident’s Personal Information.]

Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

Providing Services: Provision of our services.
Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
Personalization: Personalizing your experience on our services such as presenting tailored content.
Deidentification and Aggregation: De- identifying and aggregating information collected through our services and using it for any lawful purpose.
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 Service 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 a current interaction with you 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 this specification and 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 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 financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
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.

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

You/Your Devices: You or your devices directly.
Users: Other users of our services.
ISPs: Internet service providers.
Analytics Providers.
Government: Government entities.
OS/Platform Provider: Operating systems and platforms.
Social Networks.
Resellers: Consumer data brokers.
Partners: Business partners.
Public: Publicly accessible sources.

Disclosure of Personal Information

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties:

ISPs: Internet service providers.
Analytics Providers.
OS/Platform Provider: Operating systems and platforms.
Vendors: Vendors and service providers.
Integrated Third Parties: Third parties integrated into our services.
Third Parties as Legally Required: Third parties as required by law and similar disclosures.
Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

Your California 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, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

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.

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 name, email address, and other information about you that you have previously provided to us to respond to your access or deletion requests.

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.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please send an email via our Contact Information section or visit our website at: zm.bc178.cc

Authorizing an Agent. To authorize an agent to make an opt-out request on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.

Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at privacy@bc178.cc or write to us at 2460 Zanker Road, San Jose, CA 95131.

Last Reviewed and Updated:
October 1, 2020