Effective Date: May 5, 2020
Special Note for Users who are not California Residents:
Flux Work, Inc. (“Flux” “we” “our” “us”) has created this policy pursuant to the California Consumer Privacy Act (“CCPA”), and it will apply to any California resident (“you”) of whom Flux may collect Personal Information (defined below), such as by use of the www.fluxwork.co website (the “Site”), or the Flux mobility platform, mobile application, application programming interfaces, and other services offered by Flux (collectively the “Services”). “Personal Information” means information that identifies, relates to, describes, is cable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include publicly available, de-identified, or aggregate consumer information as defined by CCPA.
1. Flux’s Role Under CCPA
A. Flux as a Business in California
Under CCPA framework, Flux is defined as a Business as to activities of collecting, sharing, and determining the means of processing California consumer information for Commercial Purposes. Flux may collect Personal Information about you in order to provide Services to you and our customers. Your employer may be a Flux customer (“Employer”). Commercial Purpose means to advance our commercial or economic interests.
B. Flux as a Service Provider in California
Under CCPA framework, in certain scenarios, Flux may be considered a Service Provider who processes Personal Information on behalf of a Business – your Employer may disclose your Personal Information to us for a Business Purpose pursuant to a written contract between Flux and your Employer. Business Purpose means the use of Personal Information for the Business’s or Service Provider’s operational purposes, including auditing, detecting security incidents, debugging, short-term/transient use, performing customer services, internal research, and maintain / improve / upgrade / enhance services.
2. Personal Information We May Collect
The following chart shows the categories of Personal Information that we have collected during the past twelve (12) months, the sources of such information, and the Business or Commercial Purposes for which we may use such information. For all categories of Personal Information collected, we disclose data to our service providers and other third parties to help us accomplish the Business Purposes described below, as described in more detail here.
3. Flux does not “sell” your Personal Information.
Under the CCPA, Flux does not sell (as defined by the CCPA) your Personal Information.
4. Your Rights Under CCPA
CCPA provides you with rights to control how your Personal Information is collected and shared by us as follows:
You may request access to the Personal Information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past 12 months upon appropriate verification. You may only make such requests twice per every 12 months.
You have the right to request that we delete Personal Information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your Personal Information accordingly. Your request to delete your Personal Information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.
5. Exercising Your Rights
To exercise the access and deletion rights described above, please submit a request to us by either emailing us at email@example.com, or writing to us at:
Flux Work, Inc.
44 Montgomery St., 3rd Floor
San Francisco, CA 94104
Attn: Privacy Officer Nick Ionita
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by applicable law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Verifying Your Request
Only you, or a person that you authorize to act on your behalf, may make a request related to your Personal Information. In the case of access and deletion, your request must be verifiable before we can fulfill such request.
Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or a person authorized to act on your behalf (e.g., previous transactions of person to whom request relates).
We will only use the Personal Information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority.
Please note that we may charge a reasonable fee where permitted by applicable law, which will be communicated to you, or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.
The Site and Services are intended for California residents who are the age of majority. We do not knowingly collect Personal Information from minors under the age of 16. If we become aware that we have inadvertently received Personal Information from a minor under the age of 16, we will delete such information from our records.
8. Your California Privacy Rights under the "Shine the Light" Law
Pursuant to Section 1798.83 of the California Civil Code (a separate law from the CCPA), residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via firstname.lastname@example.org.
9. Do Not Track
We currently do not respond to any Do Not Track signals or similar signals.
10. Privacy Notice Changes
We may change this Flux Supplemental California Consumer Privacy Notice from time to time without giving you notice. In addition, according to CCPA, we are required to update this Notice annually. If we decide to change this Notice, we will inform you by posting the revised Notice on the Site. Those changes will go into effect on the “Effective Date” shown in the revised Notice. By continuing to use the Site or Services, you are consenting to the revised Notice.
11. Contacting Us
If you have any questions regarding our privacy practices as it relates to this Supplemental California Consumer Privacy Notice, please contact us via email at email@example.com with the subject line, “CCPA Policy.”
PLEASE PRINT A COPY OF THIS NOTICE FOR YOUR RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.