Privacy notice addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others located in the European Economic Area, the UK, or who reside in Australia, Canada, New Zealand, or the State of California, Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia, ("consumers" or "you").  

We adopt this Notice to comply with the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles contained in the Privacy Act, Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), the UK version of the GDPR, the Privacy Act 2020 (Act) and its Information Privacy Principles, the California Shine the Lights law, the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Montana Consumer Data Privacy Act of 2024, the Oregon Consumer Privacy Act of 2024, the Texas Data Privacy and Security Act of 2024, the Utah Consumer Privacy Act of 2022, the Virginia Consumer Data Protection Act of 2023, and certain other privacy and data protection laws, as applicable (collectively, the "Statutes"). Any terms defined in the Statutes will have the same meaning when used in this Notice. Any terms used in this Notice but undefined herein shall have the meaning provided in the Privacy Policy.

As further set forth in our Privacy Policy, we may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information,” as further described in our Privacy Policy.

1. Shine the Light Law.

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits individuals who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

2. Personal Information We Sold or Disclosed for a Business Purpose. 

In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Category A - Identifiers

  • Category B - Customer records information

  • Category C - Characteristics of protected classifications under state or federal law

  • Category F - Internet or other electronic network activity information

  • Category I - Professional or employment-related information

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  • Category A - Identifiers

  • Category B - Customer records information

  • Category C - Characteristics of protected classifications under state or federal law

  • Category F - Internet or other electronic network activity information

  • Category I - Professional or employment-related information

3. Your Rights Under the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020. 

You may have the right under the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

The categories of personal information we have collected about you;

The categories of sources from which the personal information is collected;

Our business or commercial purpose for collecting or selling personal information;

The categories of third parties with whom we share personal information, if any; and

The specific pieces of personal information we have collected about you.

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

Provide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Shared for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, submit a request form on cv.co/contact.

Right to Limit Use and Disclosure of Sensitive Personal Information.

You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services.

We do not collect sensitive personal information.

Right to Correction

You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records; and

Direct any service providers to delete your personal information from their records.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

Deny goods or services to you;

Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

Provide a different level or quality of goods or services to you; or

Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

4. Your Rights Under Other State Privacy Laws.

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia, also provide consumers who are residents of these states with certain rights regarding their Personal Data. This section describes the rights you may have under these state privacy laws, under certain circumstances and subject to certain exceptions. Please contacts us if you have any questions about your rights under these state privacy laws. 

Consumer Right

Explanation

Applies to Residents of:

The Right to Opt-Out

You may have the right to opt out of the processing of Personal Data concerning you for the purposes of: 

Targeted Advertising;

The Sale of Personal Data; or

Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia

The Right of Access

You may have the right to confirm whether we are processing Personal Data concerning you and to access your Personal Data.

Please note, there may be restrictions on how often you may exercise this right.

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia

The Right to Correction

You may 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 your Personal Data.

Colorado, Connecticut, Montana, Oregon, Texas, Virginia

The Right to Deletion

You may have the right to delete Personal Data concerning you or to request that we delete Personal Data provided by, or obtained about, you.

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia

The Right to Data Portability

You may have the right to obtain a copy of your Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. 

Please note, there may be restrictions on how often you may exercise this right.

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Utah, Virginia

The Right to Appeal

We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. 

Colorado, Connecticut, Iowa, Montana, Oregon, Texas, Virginia

5. Your Rights under the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles.

In Australia, you have certain rights under applicable the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles:

Right to Access

You have the right to access your personal information. We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with access to this information. In some circumstances, it may not be possible for us to provide you with all of your personal information, or an exception to access under the Privacy Act may apply. For example, we may not be able to give you access if it would unreasonably affect someone else’s privacy. If we do not provide access to the personal information held about you, we will tell you why.

Right to Correct

You have the right to correct any personal information we hold about you that you think is inaccurate. We will take reasonable steps to make sure that the information is corrected. We reserve the right to refuse to correct your personal information in some circumstances. If we refuse to correct any personal information about you, and we cannot reach a subsequent agreement, you may request that a note or statement regarding the correct request be attached to the file that contains your personal information.

If you would like to exercise your right to access or correct your personal information, please contact us in accordance with the “How to Exercise Your Rights” Section below.

If you think we have breached applicable privacy law, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details in the “Contact Us” Section of our Privacy Policy. You should include your name, email address, and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you are unhappy with our response to your complaint, please let us know and we will provide you with information about the further steps you can take. You may also file a complaint with the Office of the Australian Information Commissioner. 

6. Canada’s Personal Information Protection and Electronic Documents Act.

The Personal Information Protection and Electronic Documents Act (PIPEDA) provides consumers who are Canadian residents with specific rights regarding their Personal Information. This section describes your rights under PIPEDA and explains how to exercise those rights.

  • You have a right to know how your Personal Information will be used. We will explain why we need your Personal Information before or when we collect it, if the purpose is not already clear.

  • We will collect Personal Data only for the purposes we’ve identified or for the primary uses described in our Privacy Policy. We shall collect information by fair and lawful means only.

  • We will not use or disclose your Personal Data other than for the purposes for which it was collected unless we receive your consent or unless we are required or permitted to by law.

  • We will keep your Personal Information only for as long as it needs to for the purposes identified in our Privacy Policy, as required by law, or as necessary to resolve any disputes you may have concerning our Portal or Services. We will follow internally set guidelines and use care in the disposal, destruction, or de-identification of Personal Information to prevent unauthorized parties from gaining access to such Personal Information.

  • We will maintain accurate, complete and up-to-date Personal Information as required for the identified purposes associated with its collection. Please let us know if your contact or other Personal Information changes.

  • Upon your written request, and subject to exceptions as permitted or mandated by law, we will inform you of the existence, use and disclosure of your Personal Information and will give you access to that Personal Information. You may challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.

We maintain procedures for addressing and responding to all inquiries or complaints from you about our handling of Personal Information. We will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. We may seek external advice where appropriate before providing a final response to individual complaints. We shall investigate all complaints. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and procedures.

7. Your Rights Under the General Data Protection Regulation and the UK GDPR.

In some regions (like the European Economic Area and the UK), you have certain rights under the General Data Protection Regulation (GDPR), UK GDPR, applicable data protection laws.

Right to Access

The right to be provided with a copy of your personal information (the right of access).

Right to Rectification

The right to require us to correct any mistakes in your personal information.

Right to be Forgotten

The right to require us to delete your personal information—in certain situations.

At your request, we will delete your personal data promptly if:

it is no longer necessary to retain your personal data;

you withdraw the consent which formed the basis of your personal data processing;

you object to the processing of your personal data and there are no overriding legitimate grounds for such processing;

the personal data was processed illegally; or

the personal data must be deleted for us to comply with our legal obligations.

We will decline your request for deletion if processing of your European Personal Data is necessary:

to comply with our legal obligations;

in pursuit of a legal action;

to detect, predict and monitor fraud; or

for the performance of a task in the public interest.

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data, if your personal data was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal data, we no longer need to process your persona data, but you require your personal data in connection with a legal claim, or you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.

We may continue to store your European Personal Data to the extent required to ensure that your request to limit the processing is respected in the future.

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations. At your request, we will provide you free of charge with your European Personal Data in a structured, commonly used and machine-readable format, if:

• you provided us with personal data;

• the processing of your personal data is based on your consent or required for the performance of a contract; or

• the processing is carried out by automated means.

Right to Object

The right to object:

• at any time to your personal information being processed for direct marketing (including profiling);

• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

We will comply with your request unless we have compelling legitimate grounds for the processing which override your rights and freedoms, or where the processing is in connection with the establishment, exercise or defense of legal claims. Please note that even if we stop all marketing communications, you may still receive administrative communications from us.

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, unless you have given us your explicit consent or where they are necessary for a contract with us.

Right to withdraw consent

You have the right to withdraw any consent you may have previously given us at any time.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.  The current list of supervisory authorities who may be contacted are provided HERE.

8. Your Rights Under the Privacy Act 2020 (Act) and its Information Privacy Principles.

In New Zealand, you have certain rights under the Privacy Act 2020 (Act) and its Information Privacy Principles:

Right to be Informed

The right, except where an exception applies,  for you to be informed of the fact that your information is being processed, the intended recipients, the name and address of the company holding the personal information, the law under which the personal information is collected (and whether it is voluntary or mandatory), the consequences if the personal information is not required and the rights of access to and correction of such information.

Right to Access

The right to confirm as to whether (or not) Company holds information about you and the right to access such personal information, where such personal information may be readily retrieved.

Right to Rectification

The right to request correction of your personal information to the information is accurate, up to date, and not misleading.

If you would like to exercise your right to access or correct your personal information, please contact us in accordance with the “How to Exercise Your Rights” Section below.

9. How to Exercise Your Rights. 

If you would like to exercise any of your rights as described in this Privacy Notice, please:

  • Complete a data subject request form available on our Site at cv.co/contact;

  • Call us, toll-free, at +1(855)416-8510; or

  • Email us at support@cv.co

Please note that you may be restricted on the number of data access or data portability disclosures you may make within a 12-month period.

If you choose to contact us to exercise your rights, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In order to help protect your privacy and maintain security, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address, email address, telephone number, or customer or matter reference number);

  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

  • A description of what right you want to exercise and the information to which your request relates.

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

You may use a representative, called an "authorized agent," to submit a request to us. 

In some states, an authorized agent must be a natural person, or a business entity registered with the appropriate Secretary of State, that you have authorized to act on your behalf. 

In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request, and you must provide the authorized agent with signed permission. "Signed" means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. In California, an authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but in such cases, consumer verification will not be required.

Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. 

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.