United States Regional Privacy Notice
Effective January 1, 2023
This United States Regional Privacy Notice is for people living in the United States and supplements the Granicus Privacy Policy.
This Privacy Policy explains how we collect, use, and disclose your Personal Information. It also describes how to exercise your rights under the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, the Delaware Online Privacy and Protection Act and the Virginia Consumer Data Protection Act. We call those laws collectively the “U.S. Privacy Laws.”
Categories of Personal Information we have collected, for of which we have disclosed for a business purpose, in the preceding 12 months are:
Data Collected | When | Purpose |
Your name, business or personal email address, business or personal address, business or personal telephone number, or any other personal data you choose to share. | When you visit any of our websites, or where you use our contact functionality and or chatbot on the websites. | To contact you occasionally regarding our services and products, subject to applicable laws (for example, where required, subject to your consent). |
Information about your job, such as your position, title, management level, work location, division, department, and position level. | When registering to a webinar or other event on the website; or other ad hoc forms that we may add to the website on occasion. | To process your registration and participation in a webinar or other event to you which you have registered. To contact you occasionally regarding our services and products, subject to applicable laws (for example, where required, subject to your consent). |
Information about your access to our network and premises. | CCTV images, when visiting our premises, when you swipe a card access, time recording software and internet access usage. | To comply with our business, regulatory and legal obligations. |
IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser. | When you agree to the use of cookies and when you provide data passively (by using the website, by navigating the screens, clicking on buttons etc.) | To improve, modify and update services and content offered on the website. To monitor and ensure the orderly and proper operation and development of the website and associated services. To analyse and provide statistical information to third parties. To improve and customize your experience and the content that is presented to you on the website. |
CV, resume, name, email, phone number, and professional experience. | When you seek a career opportunity on our website processing of personal data is subject to and is governed by the Granicus Candidate Privacy Policy located here. | To process your application. |
The sources we have collected this Personal Information from are: directly from California residents or their representatives.
In the past 12 months, however, we have not “sold” Personal Information relating to California residents within the meaning of the CCPA. For purposes of this Privacy Notice, “sold” means the disclosure of Personal Information for monetary or other valuable consideration.
We may disclose this type of information to:
Service Providers, third parties who may acquire your information as a result of a merger, acquisition or other ownership transition, third parties or affiliated companies when you agree to or direct that we share your information with them, other third parties (including government agencies) as required by law or in connection with court proceedings; third party advertising, analytics, business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.
Your Consumer Request Rights Under U.S. Privacy Laws
Where applicable and subject to exceptions you, have the right to request:
- that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”);
- that we delete information we have collected from you.
- that we correct inaccurate Personal Information we hold about you (“Right to Correct”);
- to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”);
- to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”). To opt-out of cookies and other tracking technologies set by Granicus and its third party business partners that are potentially “sales” under the CPRA, open the Cookie Preference Center and Cookie Policy; and
- that we limit the use or disclosure of your Sensitive Personal Information to the purposes set forth in the statute, including the use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit the Use and Disclosure of Sensitive Personal Information”), Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when such use does not fall within the list of exceptions outlined in CPRA § 7027, subsection (l). Granicus’ use and disclosure of Sensitive Personal Information falls within this list of exceptions and we therefore do not offer such opt-out right at this time.
- California and Delaware law require to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Notice and does not monitor or respond to Do Not Track browser requests.
Submitting a Request and Verification
In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate and respond to it.
Before Granicus is able to respond to any request, we may ask to verify your identity by providing us with certain information or identification. In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights, such as information relating to our employees and contractors that is used for our employment and vendor management purposes.
When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request. Pursuant to the CPRA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sharing, Right to Opt-Out of Sale, or Right to Limit the Use and Disclosure of Sensitive Personal Information.
Authorized Agents
If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request, and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
California consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising your CCPA and CPRA rights.
Data Retention
Grancius will not retain Personal Information for longer than is reasonably necessary for each disclosed purpose outlined in this California Privacy Notice. We store personal information for as long as necessary for the purposes for which it was collected or which you subsequently authorize it and otherwise to carry out the purposes described in this Privacy Notice.
Users Younger than 16
Granicus does not knowingly collect or sell Personal Information of users younger than 16 years of age.
Notice to Virginia Residents
We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
If you are a Virginia Consumer and would like to exercise your rights pursuant to the Virginia Consumer Data Protection Act (VCDPA), and any implementing regulations adopted thereunder, please please email: dpo@granicus.com to submit a request.
Virginia Consumers have the following rights, all subject to the meanings and exceptions set forth in the VCDPA:
- To confirm whether we are processing your Personal Data and request to access such data (“Right to Access”).
- That we correct inaccurate Personal Data we hold about you (“Right to Correct”).
- That we delete the Personal Data provided by you or obtained about you (“Right to Delete”).
- To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability (“Right to Obtain”).
- To opt-out out of the processing of your Personal Data for the purposes of targeted advertising (“Right to Opt-Out of Targeted Advertising”).
Granicus engages in online advertising practices (and certain analytics or similar activities) that may be considered “targeted advertising” under the VCDPA. To disable sharing through cookies set by 3rd parties that may be considered targeted advertising under the VCDPA, click here: Cookie Policy
Granicus does not sell Personal Data to third parties for monetary compensation.
VCDPA Appeals
Pursuant to the VCDPA, if, for any reason, you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by emailing the dpo@granicus.com Please include your full name, the basis for your appeal, and any additional information to consider.
Notice to Nevada Residents
Granicus does not currently sell your covered information as those terms are defined under applicable Nevada law.