California Consumer Privacy Act Privacy Notice

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Direqt, Inc. https://www.direqt.io/privacy (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice. 

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

     - Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons,          pixel tags, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or         probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
     - Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, education, credit card number,         debit card number, and other financial information
     - Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender, and gender         identity
     - Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history,         and information regarding your interaction with websites, applications or advertisements
     - Sensory Information: audio, electronic, visual, and similar information
     - Employment Information: professional or employment-related information

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA:

     - Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and         transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics         services, or providing similar services
     - Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to         unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
     - Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
     - Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for         that activity
     - Debugging to identify and repair errors that impair existing intended functionality
     - Undertaking internal research for technological development and demonstration
     - Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or         controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled         by us.

2. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

     - Directly from you, such as when you register an account on our Service
     - Your devices, such as when you interact with our Service
     - Other individuals or organizations such as when your employer signs you up for a subscription to our Service
     - Our affiliates
     - Vendors who provide services on our behalf
     - Our providers (i.e., qualified resellers)
     - Data analytics providers
     - Government entities
     - Operating systems and platforms

3. Sale of Personal Information

We do not sell consumers’ personal information.

4. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information                                                      Category of Third Party

Identifiers                                                         
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                         Professional services organizations, such as law firms and auditors
                                                                                                                        Data analytics providers
                                                                                                                        Internet services providers
                                                                                                                        Operating systems and platforms


Additional Data Subject to Cal. Civ. Code § 1798.80 Law                         
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                        Professional services organizations, such as law firms and auditors
                                                                                                                        Data analytics providers
                                                                             

Protected Classifications                                  
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                        Professional services organizations, such as law firms and auditors


Online Activity
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                        Professional services organizations, such as law firms and auditors
                                                                                                                        Data analytics providers
                                                                                                                        Internet services providers
                                                                                                                        Operating systems and platforms


Sensory Information
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                        Professional services organizations, such as law firms and auditors


Employment Information
                                                                                                                        Our affiliates
                                                                                                                        Vendors who provide services on our behalf
                                                                                                                        Professional services organizations, such as law firms and auditors


In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with government entities.

5. California Consumer Privacy Rights

You may have certain choices regarding your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You may have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: California law provides consumers with the right to opt-out of the sale of personal information. We do not sell consumers’ personal information.

How to Submit a Request. To submit an access or deletion request, please email us at:  dpo@direqt.io

You can also write to us or contact our Data Protection Officer:

Direqt, Inc.
800 5th Ave
#101-326
Seattle, WA 98104
Phone: 206.203.7331

Verifying Requests. Your request should be made to us in writing by email to dpo@direqt.io and we may ask you for proof of your identity before providing you with the data. 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 information.  You may also make a verifiable consumer request on behalf of your minor child.  You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must:

     - 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.

Response timing and format. We endeavor to respond to a verifiable consumer request within 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.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  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. 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 requests warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
For questions or concerns about our privacy policies and practices, please contact us as described in the “How to Submit a Request” section of our Privacy Policy.

Updates to our Privacy Policy

From time to time we may update, amend and modify our privacy policies. We will also post an updated copy on our website. Please check our site periodically for updates. We will post any revised notice on our website, or a similar site that replaces our website.

Contact Us

If you have any questions or comments about this Privacy Notice for California Residents, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:

Data Protection Officer
Direqt, Inc.
800 5th Ave
#101-326
Seattle, WA 98104
Phone: (206) 203-7331Email: dpo@direqt.io
Effective Date: February 5th, 2021