CCPA and CPRA Information

Through our Site, Platform and Services, we collect information that can be used to identify or describe you or that could reasonably be linked, directly or indirectly, with a particular consumer or device as defined in the California Consumer Privacy Act (CCPA) (“Personal Information”).

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Sensitive Personal Information (SPI)

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Sensitive Personal Information (SPI) refers to specific data categories that require additional protections. ClickGuard does not collect sensitive data such as government-issued identifiers (e.g., Social Security Numbers, Driver’s License), biometric data, racial or ethnic origin, religion, genetic data, or financial account details. We do not process or retain any data categorized as sensitive under applicable privacy regulations, including CCPA/CPRA.

As explained in more detail in our Privacy Policy, ClickGuard obtains Personal Identifiable Information (PII) from the following categories of sources:

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• Directly from you
• For example, when you sign up to receive information from ClickGuard, to register an account with ClickGuard or to use our Platform or Services; and
• Indirectly through other sources
• For example, from observing your actions on our Site, including by the use of cookies, or from third parties.

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The purposes for which we use the Personal Data we collect are set out in our Privacy Policy. We refer to them as legitimate business purposes in our Privacy Policy (https://www.clickguard.com/privacy-policy) and in this Information document.

For example, we collect the following categories of Personal Information from California consumers:
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• Information that can be used to identify you ("Identifiers")
  Examples include: a real name, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
  Uses: We use Identifiers for all of our legitimate business purposes.
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• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  Examples include: a name, signature, address, telephone number, employment.
  Uses: To provide access to the Platform and Services, improve your experience, and analyze usage for functionality and product development.
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• Protected classification characteristics under California or federal law
  Examples include: birth year, gender.
  Uses: To improve your experience with the Platform and Services, and to analyze usage for functionality and development.
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• Commercial information
  Examples include: records of products purchased or considered, purchasing or consuming histories or tendencies.
  Uses: To process payments, enhance your experience, and analyze usage for technical functionality and product development.
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• Internet or other similar network activity
  Examples include: browsing history, interactions with a website or application.
  Uses: To improve your experience, and to analyze how you interact with the Platform and Services for technical functionality.
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• Geolocation data
  Examples include: physical location or movements.
  Uses: To protect against fraud and provide technical functionality.
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• Sensory data
  Examples include: video and audio recordings, visual information.
  Uses: To provide access to the Platform and Services, enhance your experience, and analyze interactions for technical functionality.
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ClickGuard will not collect additional categories of Personal Information or use the collected information for unrelated or incompatible purposes without providing notice.

Automated Decision-Making & Profiling‍
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ClickGuard does not use automated decision-making systems, AI-based profiling, or automated data processing that results in legal or significant impacts on users.
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We disclose your Personal Information for a legitimate business purpose to the following categories of third parties:

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Companies that perform tasks to help us provide the following Services: hosting service providers, user engagement and customer support providers, job application service providers, payment service providers, communication tools, and analytics tools; and

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Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

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ClickGuard may share your Personal Information with a third party for a legitimate business purpose. When we disclose Personal Information for a legitimate 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 services for us.

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In the preceding twelve (12) months, ClickGuard has not sold any Personal Information as contemplated under the CCPA.

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ClickGuard does not sell personal data as defined under CCPA/CPRA. However, ClickGuard may engage in data-sharing practices that fall under the CPRA’s expanded definition of “sharing,” including:

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Cross-context behavioral advertising (e.g., analytics for ad performance measurement).

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Marketing integrations with third-party tools.

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Opt-Out Mechanism: California residents can opt out of such sharing via the “Do Not Sell or Share My Personal Information” link provided on ClickGuard's website.

The CCPA provides California Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

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In addition to existing CCPA rights, the CPRA grants California consumers additional rights:

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Right to Correction: You can request ClickGuard to correct inaccurate personal information we maintain.

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Right to Opt-Out of Sharing: ClickGuard does not sell personal information, but consumers can now opt out of sharing personal data for cross-context behavioral advertising.

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Right to Know Retention Periods: ClickGuard will now disclose how long each data category is retained.

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ClickGuard’s services are intended for business entities and are not designed for individuals under 16. ClickGuard does not knowingly collect or process personal data of minors under 16 years old. If you are a California resident under 16 (or the parent of a minor under 16), you may exercise explicit opt-in consent for any data collection related to minors.

ClickGuard will retain personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. The retention period varies based on the type of data: 

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Account and Contact Information: Retained as long as you maintain an active ClickGuard account. 

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Payment Information: Retained per tax and financial regulations.

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Deleted Account Data: Upon deletion requests, ClickGuard will permanently erase all personal data, except where retention is legally required.

You have the right to request that ClickGuard disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of Personal Information we collected about you.

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• The categories of sources for the Personal Information we collected about you.
• Our legitimate business purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a legitimate business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a legitimate business purpose, identifying the Personal Information categories that each category of recipient obtained.

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You have the right to request that ClickGuard 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, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

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We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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• Complete the transaction for which we collected the Personal Information, provide a good or service that our customers purchase or request, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. PenalCode § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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

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• Calling us at: (888) 877‒1882
• Emailing us at privacy@ClickGuard.com
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Only you, or a person registered with the California Secretary of State 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.

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You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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• 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.
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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.

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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.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically.

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, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

ClickGuard complies with CPRA enforcement mechanisms and recognizes the authority of the California Privacy Protection Agency (CPPA). In case of a data breach or non-compliance, California residents have the right to: File a complaint with the CPPA. Seek statutory damages for violations under CPRA. Request a report of any data breach affecting their personal information.

If you have any questions or comments about this notice, the ways in which ClickGuard collects and uses your information described below and in this CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at privacy@ClickGuard.com or by mail:
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ClickGuard INC
221 W 9th St, Ste 318, 

Wilmington, DE 19801, USA