PRIVACY POLICY AND NOTICE AT COLLECTION

Effective Date: August 18, 2025
Time of Inclusion: 12:00 PM Pacific Standard Time

This Privacy Policy (“Policy”) constitutes the legally mandated notice at collection pursuant to California Civil Code § 1798.100(b) and serves as the comprehensive privacy disclosure required under the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”), for KevinFaler.com, a [business entity type] (“Business,” “we,” “us,” or “our”). This Policy governs all personal information processing activities conducted by Business and is incorporated by reference into our Terms & Conditions, which contain additional contractual provisions governing the relationship between Business and users.

I. STATUTORY AUTHORITY AND SCOPE

This Policy is promulgated pursuant to California Civil Code § 1798.130(a)(5) and constitutes Business’s consumer privacy disclosure as mandated by California law. The Policy applies to all “personal information” as defined in Cal. Civ. Code § 1798.140(o), collected from “consumers” as defined in Cal. Civ. Code § 1798.140(g), in connection with Business’s commercial activities within the State of California.

II. LEGAL DEFINITIONS

The following definitions apply to this Policy and are derived from Cal. Civ. Code § 1798.140:

“Business” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, as defined in Cal. Civ. Code § 1798.140(c).

“Consumer” means a natural person who is a California resident, as defined in Cal. Civ. Code § 1798.140(g), however identified, including by any unique identifier.

“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, as enumerated in Cal. Civ. Code § 1798.140(o).

“Processing” means any operation or set of operations performed on personal information or sets of personal information, as defined in Cal. Civ. Code § 1798.140(ac).

“Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for monetary or other valuable consideration, as defined in Cal. Civ. Code § 1798.140(ad).

“Share” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, as defined in Cal. Civ. Code § 1798.140(ah).

“Third Party” means a person who is not any of the following: (1) the business that collects personal information from consumers; (2) a person to whom the business discloses a consumer’s personal information for a business purpose pursuant to a written contract; or (3) a person covered by the definition of service provider or contractor, as defined in Cal. Civ. Code § 1798.140(ai).

III. CATEGORIES OF PERSONAL INFORMATION SUBJECT TO COLLECTION

Pursuant to Cal. Civ. Code § 1798.100(b), Business hereby provides notice that it collects the following categories of personal information as enumerated in Cal. Civ. Code § 1798.140(o):

A. Identifiers (Cal. Civ. Code § 1798.140(o)(1)(A))

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

B. Personal Information Categories Listed in Cal. Civ. Code § 1798.80(e)

Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

C. Protected Classification Characteristics (Cal. Civ. Code § 1798.140(o)(1)(C))

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.

D. Commercial Information (Cal. Civ. Code § 1798.140(o)(1)(D))

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric Information (Cal. Civ. Code § 1798.140(o)(1)(E))

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.

F. Internet or Other Similar Network Activity (Cal. Civ. Code § 1798.140(o)(1)(F))

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

G. Geolocation Data (Cal. Civ. Code § 1798.140(o)(1)(G))

Physical location or movements.

H. Sensory Data (Cal. Civ. Code § 1798.140(o)(1)(H))

Audio, electronic, visual, thermal, olfactory, or similar information.

I. Professional or Employment-Related Information (Cal. Civ. Code § 1798.140(o)(1)(I))

Current or past job history or performance evaluations.

J. Non-Public Education Information (Cal. Civ. Code § 1798.140(o)(1)(J))

Per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99).

K. Inferences (Cal. Civ. Code § 1798.140(o)(1)(K))

Drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

IV. SENSITIVE PERSONAL INFORMATION COLLECTION NOTICE

Pursuant to Cal. Civ. Code § 1798.121, Business may collect the following categories of sensitive personal information as defined in Cal. Civ. Code § 1798.140(ae):

  1. Personal information revealing a consumer’s social security, driver’s license, state identification card, or passport number;
  2. Personal information revealing a consumer’s 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 an account;
  3. Personal information revealing a consumer’s precise geolocation;
  4. Personal information revealing a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
  5. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication;
  6. Personal information revealing a consumer’s genetic data;
  7. Biometric information processed for the purpose of uniquely identifying a consumer;
  8. Personal information collected and analyzed concerning a consumer’s health; and
  9. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

V. SOURCES OF PERSONAL INFORMATION COLLECTION

Personal information is collected from the following sources pursuant to Cal. Civ. Code § 1798.110(a)(4):

  1. Direct Consumer Interaction: Information provided voluntarily through forms, communications, account registration, and service utilization;
  2. Automatic Collection Technologies: Cookies, web beacons, pixels, session storage, and similar tracking technologies as governed by Cal. Bus. & Prof. Code § 22575 et seq.;
  3. Third-Party Service Providers: Vendors, contractors, and service providers operating under written agreements pursuant to Cal. Civ. Code § 1798.140(ag);
  4. Publicly Available Sources: Information lawfully made available from federal, state, or local government records;
  5. Social Media Platforms: When consumers elect to interact with Business’s social media presence;
  6. Business Partners: Entities with whom Business maintains contractual relationships for legitimate business purposes.

VI. BUSINESS AND COMMERCIAL PURPOSES FOR PROCESSING

Pursuant to Cal. Civ. Code § 1798.100(b) and § 1798.110(a)(5), personal information is processed for the following purposes:

A. Business Purposes (Cal. Civ. Code § 1798.140(d)):

  1. Auditing Consumer Interactions: Counting ad impressions and verifying positioning and quality of ad impressions;
  2. Security and Fraud Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting responsible parties;
  3. Debugging: Identifying and repairing errors that impair existing intended functionality;
  4. Transient Use: Short-term, transient use, provided personal information is not disclosed to third parties and is not used to build profiles or otherwise alter consumer experience outside current interaction;
  5. Service Performance: Providing services on behalf of the business or service provider, 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;
  6. Internal Research: For technological development and demonstration;
  7. Quality Assurance: Undertaking activities to verify or maintain the quality or safety of services and to improve, upgrade, or enhance services;
  8. Legal Compliance: Complying with applicable federal, state, or local laws, rules, or regulations.

B. Commercial Purposes (Cal. Civ. Code § 1798.140(f)):

Processing personal information to advance Business’s commercial or economic interests, including but not limited to: inducing consumers to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services; enabling commercial transactions; or otherwise advancing commercial or economic interests.

VII. CATEGORIES OF THIRD-PARTY RECIPIENTS

Pursuant to Cal. Civ. Code § 1798.110(a)(6), Business may disclose personal information to the following categories of third parties:

  1. Service Providers (Cal. Civ. Code § 1798.140(ag)): Entities processing personal information on behalf of Business pursuant to written contracts;
  2. Contractors (Cal. Civ. Code § 1798.140(j)): Natural persons or legal entities providing services to Business;
  3. Government Entities: Federal, state, and local agencies when legally compelled by subpoena, court order, or other lawful process;
  4. Professional Service Providers: Attorneys, accountants, auditors, and consultants bound by professional confidentiality obligations;
  5. Corporate Transaction Participants: In connection with mergers, acquisitions, asset sales, or similar transactions;
  6. Affiliated Entities: Companies under common ownership or control with Business.

VIII. SALE AND SHARING DISCLOSURES

A. Sale of Personal Information (Cal. Civ. Code § 1798.115)

Business [DOES/DOES NOT] sell personal information as defined in Cal. Civ. Code § 1798.140(ad). [If applicable: The categories of personal information sold in the preceding 12 months include: [specify categories].]

B. Sharing for Cross-Context Behavioral Advertising (Cal. Civ. Code § 1798.115)

Business [DOES/DOES NOT] share personal information for cross-context behavioral advertising as defined in Cal. Civ. Code § 1798.140(ah). [If applicable: The categories of personal information shared include: [specify categories].]

IX. RETENTION SCHEDULE

Personal information retention periods are established pursuant to legitimate business needs and legal requirements, including but not limited to:

  • California Code of Regulations, Title 2, § 999.317(g)
  • Industry-specific retention requirements
  • Litigation hold obligations
  • Tax record retention under Internal Revenue Code provisions
  • Employment record retention under California Labor Code requirements

X. CONSUMER RIGHTS UNDER CCPA/CPRA

California consumers possess the following statutory rights:

A. Right to Know (Cal. Civ. Code § 1798.110 & § 1798.115)

The right to request disclosure of: (1) categories of personal information collected; (2) categories of sources; (3) business or commercial purpose; (4) categories of third parties; and (5) specific pieces of personal information collected.

B. Right to Delete (Cal. Civ. Code § 1798.105)

The right to request deletion of personal information collected, subject to exceptions enumerated in Cal. Civ. Code § 1798.105(d).

C. Right to Correct (Cal. Civ. Code § 1798.106)

The right to request correction of inaccurate personal information maintained by Business.

D. Right to Opt-Out (Cal. Civ. Code § 1798.120 & § 1798.135)

The right to direct Business to stop: (1) selling personal information; and (2) sharing personal information for cross-context behavioral advertising.

E. Right to Limit Use and Disclosure of Sensitive Personal Information (Cal. Civ. Code § 1798.121)

The right to limit Business’s use and disclosure of sensitive personal information to purposes specified in Cal. Civ. Code § 1798.121(a).

F. Right to Non-Discrimination (Cal. Civ. Code § 1798.125)

The right to non-discriminatory treatment for exercising CCPA rights, subject to permissible differences in price or service quality pursuant to Cal. Civ. Code § 1798.125(b).

XI. RIGHTS EXERCISE PROCEDURES

A. Request Methods (Cal. Civ. Code § 1798.130(a)(2))

Consumers may submit requests via:

  • Toll-free telephone number: 206-594-5926
  • Internet website address: PoliceOfficer.com
  • Email address: legal@kevinfaler.com

B. Identity Verification (California Code of Regulations, Title 11, § 7053)

Business employs commercially reasonable verification methods consistent with the sensitivity and value of personal information, including matching request information against Business records and requiring additional documentation when necessary.

C. Authorized Agent Procedures (Cal. Civ. Code § 1798.135(b))

Authorized agents must provide: (1) power of attorney pursuant to California Probate Code §§ 4000-4465; or (2) written authorization and consumer identity verification.

D. Response Timeline (Cal. Civ. Code § 1798.130(a)(2))

Business shall respond to verified requests within forty-five (45) days, with one permissible forty-five (45) day extension upon notice to consumer.

XII. MINOR’S PRIVACY PROTECTION

Pursuant to Cal. Civ. Code § 1798.120(c), Business does not sell or share personal information of consumers under sixteen (16) years of age without affirmative authorization. For consumers between thirteen (13) and sixteen (16) years of age, the consumer may provide such authorization. For consumers under thirteen (13) years of age, the consumer’s parent or guardian must provide such authorization.

XIII. CALIFORNIA SHINE THE LIGHT DISCLOSURE

Pursuant to Cal. Civ. Code § 1798.83, California residents may annually request information regarding disclosure of personal information to third parties for direct marketing purposes during the preceding calendar year.

XIV. SECURITY MEASURES

Business implements reasonable security procedures and practices pursuant to Cal. Civ. Code § 1798.81.5, including administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, use, modification, or disclosure.

XV. COOKIE POLICY AND DO NOT TRACK

Business’s cookie usage complies with Cal. Bus. & Prof. Code § 22575(b). Business [DOES/DOES NOT] respond to “Do Not Track” signals as defined in Cal. Bus. & Prof. Code § 22575(b)(7).

XVI. POLICY AMENDMENTS

Material changes to this Policy shall be communicated through conspicuous notice pursuant to California Code of Regulations, Title 11, § 7012, with updated effective dates prominently displayed.

XVII. CONTACT INFORMATION AND DISPUTE RESOLUTION

Designated Privacy Officer:
KevinFaler.com
Telephone: 206-594-5926
Email: info@kevinfaler.com

Consumer inquiries and complaints may also be directed to the California Attorney General at: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company

XVIII. SEVERABILITY AND GOVERNING LAW

This Policy shall be governed by the laws of the State of California. If any provision is deemed unenforceable, the remainder shall remain in full force and effect. Additional terms governing the relationship between Business and consumers are set forth in the Terms & Conditions, which are incorporated herein by reference and contain mandatory arbitration provisions and class action waivers as permitted under California law.

ACKNOWLEDGMENT: This Policy constitutes a legally binding agreement between Business and consumers. By accessing or using Business’s services, consumers acknowledge receipt of this notice and consent to the processing described herein, subject to applicable law.

Document executed and effective as of August 18, 2025, 12:00 PM Pacific Standard Time.

Client Inquries: 167