Privacy Notice for California Residents

Last Updated: May 18, 2023

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in Marinus Analytics LLC’s Privacy Policy (the “Privacy Policy”) and applies solely to individuals who reside in the State of California ("you"). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, each as they may be amended from time to time (collectively, the “CCPA”) and any terms defined in the CCPA, including “consumers”, “personal information”, “sell”, “share”, “cross-context behavioral advertising”, and “sensitive personal information,” have the same meaning when used in this Notice.  Capitalized terms not otherwise defined herein shall have the meanings set forth in the Privacy Policy.  

Information We Collect

We collect personal information about you, as further described in this Notice. Personal information does not include:

• Publicly available information from government records.

• Deidentified, aggregated, or anonymized information that is maintained in a form that is not capable of being associated with or linked to a California consumer.

• Information excluded from the CCPA's scope, including:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;

• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or services of ours that you use.

• Indirectly from you. For example, from observing your actions on our website, www.marinusanalytics.com (the “Website”) or Traffic Jam tool or from automated data collection technologies in connection therewith.

• From information you post, or that is posted about you, in online advertisements or postings on publicly available websites or services to further our efforts to combat human trafficking. Individuals who are the subject of such online advertisements or postings are referred to in this Notice as “Ad Subjects.”

Additionally, in the past twelve (12) months, we have collected the following categories of sensitive personal information from California consumers who are either Ad Subjects or the subject(s) of our clients’ investigations:

·      Facial recognition scanning imagery;

·    Information concerning a consumer’s sex life or sexual orientation. 

The purpose for our collection of the above-described categories of sensitive personal information is to help law enforcement and others identify and rescue victims of human trafficking, hinder or halt such activity, and support them in the prosecution of those engaging in human trafficking. The sources of these types of sensitive personal information are publicly available websites or services providing relevant advertisements or postings. 

Use of Personal Information

We may use or disclose the personal information and sensitive personal information we collect for one or more of the following purposes:

• To enable us to provide our services to law enforcement and other customers relating to the identification of human trafficking activity and efforts to stop or hinder that activity and prosecute those who violate laws relating to human trafficking.

• To support academic or other collaborations for research purposes relating to human trafficking activity with the ultimate goal of stopping or hindering such activity and prosecuting those who violate laws relating to human trafficking.

• To provide, support, personalize, and develop our Website, products, and services, including our Traffic Jam tool.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services, including our Traffic Jam tool.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information and sensitive personal information or as otherwise set forth in the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information and sensitive personal information held by us about our consumers is among the assets transferred.

We may sell the personal information and sensitive personal information that we collect regarding Ad Subjects only to enable us to provide our services to law enforcement and other customers relating to the identification of human trafficking activity and efforts to stop or hinder that activity and prosecute those who violate laws relating to human trafficking.

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

Disclosures of Personal Information

We may disclose your personal information and sensitive personal information to a third party for a business purpose. We only make these business purpose disclosures under legally enforceable written obligations that require the third party to keep the personal information and sensitive personal information confidential and prohibit use of the disclosed information for any purpose except performing the specified services for us or as otherwise permitted under the CCPA. In the preceding twelve (12) months, we have disclosed personal information and sensitive personal information for a business purpose to the categories of third parties indicated in the chart below.

We may also disclose your personal information and sensitive personal information by selling it to third parties, subject to your right to opt-out of those sales. We do not sell personal information of our customers, users, website visitors or those on our mailing lists; we only sell personal information and sensitive personal information of Ad Subjects as part of our efforts to combat human trafficking. Our personal information sales do not include information about individuals we know are under age 16. If we become aware of a California resident under the age of 16 whose is an Ad Subject and whose personal information and/or sensitive personal information is included in sales to third parties, we will delete that information from our databases, except to report information as required by law or to assist law enforcement and others to investigate, hinder, halt and/or prosecute human trafficking and child abuse activity. In the preceding twelve (12) months, the Company has sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

In the preceding twelve (12) months, the Company has sold the sensitive personal information we collect regarding Ad Subjects to: law enforcement and other data and/or service customers for the purposes of detecting or hindering human trafficking activity (which, in addition to law enforcement agencies, include businesses, nonprofit organizations, and government entities) and academic researchers.

Marinus does not “share”, and has not “shared” in the last twelve (12) month, personal information or sensitive personal information within the meaning of the CCPA. 

Retention of Personal Information

We retain the personal information of Ad Subjects for fifteen (15) years after the information has been collected. 

With the exception of the personal information of Ad Subjects, we retain personal information and sensitive personal information for no longer than is reasonably necessary for one or more of our business purposes for using such information, subject to your right to request we delete your information. Due to the nature of the services, it is not possible to predict the length of time that we intend to retain your personal information and sensitive personal information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your personal information and sensitive personal information for one or more disclosed business purpose(s):

• whether not there is a retention period required by statute or regulations;

• the pendency of any actual or threatened litigation for which we are required to preserve the information;

• pendency of applicable statutes of limitations for potential legal claims; and

• generally accepted best practices in our industry. 

When we determine that it is no longer reasonably necessary to retain your personal information or sensitive personal information for one or more disclosed business purpose(s) based on the above criteria, we will delete your personal information and/or sensitive personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information and sensitive personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties to whom we disclose that personal information.

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

• The specific pieces of personal information we collected about you (also called a data portability request).

You also have the right to request a copy of your personal information, and/or to request that we transmit your personal information to another entity.  To the extent technically feasible, we will comply with your request and provide and/or transmit your personal information in a structured, commonly used, machine-readable format. 

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) or contractors to:

1. Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law,  provide a good or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes. 

3. Debug products and services to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the ability to complete such research , if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information; or

8. Comply with a legal obligation.

If we are able to grant your request to delete, we will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct

You further have the right to request that we correct any of your personal information that is inaccurate. Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will correct any inaccurate personal information pursuant to your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the personal information is accurate.  We may also delete your personal information instead of correcting it to the extent such deletion would not negatively impact you. 

Right to Limit the Use of Sensitive Personal Information

Lastly, you have the right to request that we limit the use and disclosure of sensitive personal information. Once we receive your request, we will limit our use of your sensitive personal information, but we may continue to use or disclose your sensitive personal information to:

1.     Complete the transaction for which we collected your sensitive personal information, provide goods or services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

 2.    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

 3.    Use the information in a short-term and transient manner, including, but not limited to, to facilitate non-personalized advertising shown as part of your current interaction with our services, but not including disclosure to third parties or use outside your current interaction with our services;

 4.    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or

 5.    Make any other uses of that information that are permitted by the CCPA and its implementing regulations.

Exercising Your Rights to Know, Correct, or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at (866) 945-2803

• Submitting your request through our webform available here: https://www.marinusanalytics.com/do-not-sell-my-personal-information

• Emailing us at privacy@marinusanalytics.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

Designating an Authorized Agent

To designate an authorized agent, you must provide the authorized agent signed permission to submit the request, (2) verify your identity directly with us, and (3) directly confirm to us that you provided the authorized agent permission to submit the request. The foregoing will not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.

Requirements for Submitting Requests

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. The information we request and the degree of verification you will need to provide will depend on the scope of your request.  Requests for copies of specific pieces of your personal information may require additional information to verify your identity as compared to general Requests to Know.  The information that we will need to verify your identity for Requests to Delete will depend on the nature of your request.  For example, we may require a reasonably high degree of certainty for verification of a request to delete documents or files.

• 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.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see the sections entitled “Personal Information Sales Opt-Out and Opt-In Rights” and “Request to Limit the Use of Sensitive Personal Information” below.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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 useable 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.

In addition, we will not honor your request where an exception under the California law applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another consumer or where the personal information we have about you is not subject to the CCPA’s access or deletion rights.  We also will advise you in our response if we are not able to honor your request for these reasons.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://www.marinusanalytics.com/do-not-sell-my-personal-information

You also may opt out as follows:

• Calling us at (866) 945-2803

• Emailing us at privacy@marinusanalytics.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by calling or emailing us at the phone number or email address immediately above.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Request to Limit the Use of Sensitive Personal Information

You have the right to direct us to limit the use of your sensitive personal information. 

To exercise this right, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://www.marinusanalytics.com/do-not-sell-my-personal-information

You also may opt out as follows:

• Calling us at (866) 945-2803

• Emailing us at privacy@marinusanalytics.com.

You do not need to create an account with us to exercise your right to limit the use of your sensitive personal information. We will only use sensitive personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@marinusanalytics.com or write us at: Marinus Analytics, PO Box 6127, Pittsburgh, PA 15212-9998.

Changes to This Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice's effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which Marinus Analytics, LLC collects and uses your information described here 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:

Phone: (866) 945-2803

Email: privacy@marinusanalytics.com

Postal Address:

Marinus Analytics, LLC

Attn: Privacy

PO Box 6127, Pittsburgh, PA 15212-9998

If you need to access this Notice in an alternative format due to having a disability, please contact privacy@marinusanalytics.com or (866) 945-2803.

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