California Notice

Effective as of: January 1, 2020

If you are a California resident and we collect your personal information, this notice (“California Notice”) applies to you (“consumers” or “you”), except as stated below.

This California Notice is in addition to the information in our privacy policy above.

The purpose of this California Notice is to ensure that we comply with our obligations under the California Consumer Privacy Act of 2018 (CCPA).

The CCPA does not apply to certain information such as de-identified or aggregated consumer information, certain publicly available information, and other personal information covered by sector-specific laws. In addition, the CCPA exempts from certain CCPA requirements the personal information about our employees, job applicants, contractors, controlling owners, directors and officers who are California residents, but provides you with certain disclosure rights. See our Notice for California Company Resources below. The CCPA also exempts from certain CCPA requirements the personal information reflecting a written or verbal business-to-business communication or transaction (“B2B personal information”).

Collection of Information

We collect 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, device or household (“personal information”).

We have collected the following categories of personal information from our California consumers within the last twelve (12) months (both online and offline):

Category in CCPA	Examples in the CCPA	Examples of Information Collected by Fuel Cycle
Identifiers	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.	Name, email address, IP address, Fuel Cycle user name, and mobile device identifier
Personal information categories listed in the California Customer Records statute	A 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.	Name, phone number, job title, and last four digits of credit card number
Protected classification characteristics under California or federal law	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 (including familial genetic information).	Age and gender if provided by our business clients
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Purchases of Fuel Cycle offerings on behalf of business client
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Directly from the consumer. Affiliated and unaffiliated service providers, including companies we retain to provide hosting, marketing, billing, collections, analytics, technical, operational, security and other services to us.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Time spent on the Site and Services and your activities on the Site and Services
Geo-location data	Physical location or movements	Location data derived from your IP address
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	Directly from the consumer.
Professional or employment-related information	Current or past job history or performance evaluations	Directly from the consumer. Third party data providers and social media platforms.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Data regarding your behavior on the Site and Service

Categories of Sources

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

Directly from you
Automatically collected information,
Our business clients,
Our service providers, and
Information when you log in with a third party’s single sign-in.

Use of Information

We may use your personal information for one or more of the following purposes:

To operate the Site and Services,
To personalize the Site and Services,
To respond to your inquiries,
To send communications,
To manage users’ accounts,
To bill for fees owed by business clients,
To measure the success of campaigns and content,
As we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, fraudulent, illegal, unethical or legally actionable activity, including abuse of our Services’ infrastructure or the Internet in general (such as spamming, denial of service attacks, or attempts to compromise the security of information, among other things), and
As described to you when we collect your personal information or as otherwise permitted under the CCPA.

If we will collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes, we will notify you.

Information Sharing

Sales of Personal Information

In the preceding twelve (12) months, we have not sold your personal information. “Sold” is defined under the CCPA.

Sharing Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose. We ask these third parties to keep the personal information confidential and not use it for any purpose except to perform the contract.

We share your personal information with the following categories of third parties:

Our affiliates
Our business clients
Our service providers
A buyer of our business
The public (voluntarily by you)

We may also share your information as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process and our legal obligations; (c) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (d) to enforce our terms and conditions; (e) to protect our operations and the security of our Services; (f) to protect our rights, privacy, safety or property, and/or that of you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers
Personal information categories listed in the California Customer Records statute,
Protected classification characteristics under California or federal law
Commercial information
Biometric info
Internet or similar network activity
Geo-location data
Sensory data
Professional or employment-related data
Non-public education records
Inference data

Your California Rights & Choices

The CCPA provides California residents with specific rights about their personal information. The CCPA does not give these rights to consumers with B2B personal information or employees and other resources.

Access & 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. Once we receive and confirm your verifiable consumer request, 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 that personal information,
The categories of third parties with whom we share that personal information, and
The specific pieces of personal information we collected about you.

When we provide you with the specific pieces of personal information about you, you may copy that information and use it for your own purposes. This allows you to exercise your data portability rights.

Deletion Right

You have the right to request that we delete any of your personal information that we collected from you and still retain. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless there is an exception to deletion that applies.

There may be circumstances where we do not delete your information or we delete only part of your information if keeping the information is necessary for us or our service providers to:

Comply with a legal obligation.
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Enable internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act.
Engage in scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How to Exercise Your Rights

To exercise your California rights above, please submit a verifiable consumer request to us by either:

Emailing us at privacy@fuelcycle.com and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).
Submitting a web form located here and providing your full name and email address and the request that you are making (e.g., right to access, portability or deletion).

The CCPA does not give these rights to consumers with B2B personal information or employees and other company resources.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.

To exercise your rights with respect to personal information held by a business client of ours, you may contact that business client directly.

Response & Timing

We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt of the request. If we need more time, we will inform you.

If you have an account with us, we may deliver our written response to that account, otherwise our response will generally be sent to your email address.

Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

We may offer certain financial incentives permitted by the CCPA that could result in different prices, rates, or quality levels. The incentive will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Notice for California Company Resources

Effective as of January 1, 2020

This Notice for California Company Resources (“Resources Notice”) applies to our employees, job applicants, controlling owners, directors, officers, independent contractors, and medical staff (if any) who reside in California (“you” or “Resource”).

The purpose of this Resources Notice is to ensure that we comply with our obligations under the California Consumer Privacy Act of 2018 (CCPA) with respect to our Resources.

Information We Collect from Resources

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a Resource in the course of the natural person acting in his/her capacity as a Resource (“personal information”).

We have collected the following categories of personal information from our Resources within the last twelve (12) months (not all information may apply to you):

Category	Examples
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, user name and password, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute	A 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.
Protected classification characteristics under California or federal law	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 (including familial genetic information).
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geo-location information	Physical location
Sensory information	Audio recordings of support-related calls and security video recordings at company offices
Professional or employment-related information	Current and past job history and performance evaluations
Non-public education information per the Family Educational Rights and Privacy Act	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Use of Personal Information of Resources

We may use the personal information of our Resources for one or more of the following purposes:

EMPLOYEES, DIRECTORS, OFFICERS, AND CONTROLLING OWNERS: We may use your information for the following purposes (not all of these may apply to you): identifying you, verifying work authorization, administering taxes and health, medical and other benefit plans, keeping track of your records, contacting you, facilitating payment to bank accounts, contributing to and administering 401(k) plans, garnishing wages required by law, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
JOB APPLICANTS: We may use your information for the following purposes: identifying you, keeping track of records, contacting you, evaluating your candidacy, performing background and reference checks, and onboarding you. See our general privacy policy for additional detail about job applicant data practices.
INDEPENDENT CONTRACTORS: We may use your information for the following purposes: identifying you, administering taxes, keeping track of your records, contacting you, facilitating payment to bank accounts, evaluating performance, tracking efficiency and productivity, protecting against disclosure of confidential information and trade secrets, and ensuring compliance with applicable laws and company policies.
Legal and Other Uses: We may also use your information if we believe it is required or appropriate: (a) to prevent or stop activity that we may think is, or is at risk of being, illegal, unethical or legally actionable activity; (b) to protect our rights, privacy, safety or property, and that of you and others; (c) to protect our operations and the security of our Services; (d) under applicable law; (e) to comply with legal process and our legal obligations; (f) to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties; (g) to enforce our terms and conditions; and (h) to allow us to pursue available remedies or limit potential damages.
We may use your information as described to you when collecting your personal information or as otherwise permitted in the CCPA.

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