Additional Notice for California Residents

Last Updated: January 1, 2024

This Additional Notice for California Residents (“CCPA Notice”) provides supplementary and important disclosures for California residents, as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). Note that certain sections of this CCPA Notice reference or link to sections contained in the Privacy Notice. Capitalized terms not defined in this Additional Notice for California Residents are defined in the Privacy Notice. You may also view our California Notice at Collection here.

As with the Privacy Notice, this CCPA Notice does not apply to Vendavo’s collection and use of personal information when it acts as a service provider. Such collection and use of personal information by Vendavo when it acts as a service provider are governed by data processing agreements with Vendavo’s customers, who are the data controllers (or businesses). 

Personal Information Collection

The following chart details (1) the categories of personal information (as listed in the CCPA) that we collect through your use of our Digital Services; (2) the sources of such personal information; and (3) the purposes of collection.

Category of Personal Information Source(s) Purposes
Identifiers
Full name; Telephone; Postal address; Email address; Unique personal or online identifier; IP address		 ·         Directly from consumers
·         Via automated means
·         From third parties		 ·         To administer our Digital Services;
·         To respond to inquiries from potential customers;
·         To register customers;
·         To market or promote new information, products or services;
·         To provide the Digital Services;
·         To communicate with customers;
·         To carry out our legal obligations and enforce our rights;
·         To monitor the safety and security of our Digital Services and offices.
Personal information categories listed in the California Customer Records statute
Full name; Addresses; Telephone number		 ·         Directly from consumers
·         From third parties		 ·         To respond to inquiries from potential customers;
·         To register customers;
·         To market or promote new information, products or services;
·         To provide the Digital Services;
·         To communicate with customers;
·         To carry out our legal obligations and enforce our rights;
·         To monitor the safety and security of our Digital Services and offices.
Internet or other electronic network activity information
IP address; Internet browsing history; Search history; Interaction with our Site and products		 ·         Via automated means ·         To administer our Digital Services;
·         To improve our Digital Services and analyze traffic to, and interactions with, our Digital Services;
·         To market or promote new information, products or services;
·         For retargeting and advertising purposes;
·         To carry out our legal obligations and enforce our rights;
·         To monitor the safety and security of our Digital Services.
Geolocation data
Location information derived from IP address		 ·         Via automated means ·         To market or promote new information, products or services, and tailor our marketing to specific geographic regions;
·         For retargeting and advertising purposes;
·         To monitor the safety and security of our Digital Services.
Audio, electronic, visual, or similar information

Audio/video recordings of meetings or events, or if you visit our offices, we may use CCTV or other surveillance to protect our property

 ·         Directly from consumers
·         From third parties		 ·         To respond to customer issues, concerns, and complaints;
·         To improve our products and services and provide customer service;
·         To monitor the safety and security of our Digital Services and offices;
·         To carry out our legal obligations and enforce our rights.
Professional or employment-related information
Job title or role; Employer name		 ·         Directly from consumers
·         From third parties		 ·         To provide and administer our products and services, including our Digital Services;
·         To respond to inquiries and otherwise communicate with customers;
·         To market or promote new information, products or services, and tailor our marketing;
·         To carry out our legal obligations and enforce our rights;
·         To monitor the safety and security of our Digital Services.
Inferences
Inferences drawn from any of the information in the categories listed above, reflecting a person’s preferences or interests		 ·         Via automated means
·         From third parties		 Note: We do not make inferences based on sensitive personal information.
·         To provide and administer our products and services, including our Digital Services;
·         To market or promote new information, products or services, and tailor our marketing;
·         To improve our Digital Services, products, and services;
·         To monitor the safety and security of our Digital Services.
Commercial information
Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies		 ·         Directly from consumers
·         Via automated means
·         From third parties		 ·         To provide and administer our products and services, including our Digital Services;
·         To process transactions;
·         To market or promote new information, products, or services;
·         To carry out our legal obligations and enforce our rights;
·         To monitor the safety and security of our Digital Services.
Sensitive Personal Information
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to a customer account		 ·         Directly from consumers ·         To provide and administer our products and services, including our Digital Services;
·         To monitor the safety and security of our Digital Services and offices;
·         To carry out our legal obligations and enforce our rights.
Note: We do not sell or share sensitive personal information.

Disclosures of Personal Information

Vendavo will disclose your personal information to the following categories of recipients or under the following circumstances:

  • Our group companies (in Sweden, the UK, the Czech Republic, India, and the USA), who provide data processing services to us in support of the delivery of our Digital Services, to provide functionality for our Digital Services, or for local marketing purposes;
  • Service providers which support the delivery of or functionality for our Digital Services, which enhance the security of our Digital Services, or which support our marketing efforts (including event planners and organizers, hotel partners, other event venues, webinar hosts or co-hosts and/or caterers);
  • Partners who work with us on the co-delivery of our Digital Services;
  • Third parties who conduct independent research, surveys, or customer or prospect interviews on our behalf;
  • Auditors who review information and documentation relating to our Digital Services to provide us with legally required financial audits or independent third-party security audits;
  • Third parties who assist with advertising and marketing;
  • An actual or potential buyer or other third party (and/or its agents and advisers) in connection with any actual or proposed purchase, merger, joint venture, or acquisition of any part of our business, or other investment in or funding for our business;
  • If any bankruptcy or reorganization proceeding is brought by or against us, third parties who may acquire or receive the information that we hold, which may be considered an asset of ours, as part of a sale or transfer;
  • To protect your vital interests, or those of another person;
  • Persons or parties to whom you instruct or direct us, or provide consent for us, to disclose your personal information; and
  • To any competent law enforcement body, government agency, court or other third party where we believe disclosure is necessary and in accordance with applicable data protection law (i) as a matter of applicable law or regulation, or (ii) to exercise, establish or defend our legal position.

Sales and Sharing of Personal Information

The categories of third parties to whom personal information may have been sold or shared and, if so, the purpose(s) for which the personal information was sold or shared are as follows:

 

Categories of Third Parties to Whom Personal Information May Have Been Sold or Shared Categories of Personal Information Purpose(s)
·         Advertising partners
·         Analytics providers		 ·         Identifiers
·         Internet activity
·         Commercial information
·         Inferences		 For advertising and marketing, including cross-context behavioral advertising

Retention

We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing lawful basis to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If at any time you wish to cease interaction with us, or request that we no longer process your personal information to provide you with services, please follow the instructions in the “How to Contact Us” section below.

Your Rights under CCPA

  1. Requests to Know, Delete, or Correct
    • Requests to Know. Subject to certain exceptions, as set forth in the CCPA, you may request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months or other CCPA-specified period: (1) the categories of personal information we collected about you; (2) the categories of sources from which we collected this personal information; (3) the categories of personal information that we have disclosed to third parties; (4) the categories of recipients to whom this personal information was disclosed; (5) the business or commercial purpose for disclosing personal information; and (6) specific pieces of personal information we have collected about you.
    • Requests to Delete. You may request that we delete personal information that we have collected from you. We may limit or deny your request to delete, in accordance with certain exceptions specified in the CCPA.
    • Requests to Correct. You may request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. We may limit or deny your request to correct, in accordance with certain exceptions specified in the CCPA.
    • Right to Opt-out of “Sale” of Personal Information or “Sharing” for targeted advertising. Vendavo does not sell your personal information in the traditional sense. However, like most online companies, we use third-party advertising and analytics services to conduct activities that may be considered a “sale” or “sharing” under CCPA. These practices utilize information obtained via cookies or other tracking technologies, and may include delivering advertising to you (e.g., targeted, or cross-context behavioral advertising) or tracking you across websites. You can get more information and opt-out of sales or sharing of personal information by clicking the cookie icon on the bottom left of the page and setting your preferences or by submitting a privacy inquiry form. Note that you will need to set your preferences from each device or web browser from which you wish to opt-out. If your browser participates in the Global Privacy Control (GPC), you may also set the Global Privacy Control (GPC) to opt-out of the “sale” or “sharing” of your personal information.
    • Non-discrimination. You have the right to be free from unlawful discriminatory treatment under the CCPA for exercising any of your CCPA rights.
  2. Use and Disclosure of Sensitive Personal Information
    Under CCPA, you have the right to direct a business that collects your sensitive personal information to limit its use of such sensitive personal information to only the use(s) necessary to perform the services or reasonably expected by the average individual who requests such services or as otherwise permitted under applicable data protection and privacy laws. We only use or disclose the limited sensitive personal information that we collect as necessary to manage your use of the Digital Services; resist malicious, deceptive, fraudulent, or illegal actions directed at our business; and ensure the physical safety of natural persons. Vendavo does not use sensitive personal information for the purpose of inferring characteristics (or outside of the necessary purposes set forth above).
  3. Exercising your Rights
    • Submit a Request. For information on your rights and how to exercise them, please visit Your Rights under CCPA above. You may also submit a privacy inquiry form or email us at privacy@vendavo.com. Please note that requests may be subject to applicable exceptions as allowed under CCPA.
    • Identity Verification. To protect your privacy and depending on the type of request, we will require you to provide information with your request that enables us to match with information we maintain to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only.
    • Authorized Agents. You may authorize a natural person or business entity to submit a request on your behalf (an “Authorized Agent“). As part of our verification process, we will require proof concerning their status as an Authorized Agent. We may also require you to directly confirm with us that you provided the agent with permission to submit the request.

How to Contact Us

If you have any questions or requests in connection with this CCPA Notice or other privacy related-matters, please contact us at privacy@vendavo.com or by mail at:

Vendavo, Inc.
c/o Privacy
1200 17th Street, Suite 1000
Denver, CO 80202