California Consumer Privacy Act (CCPA)
This Privacy Notice is provided in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), which expands upon the CCPA. It supplements the information contained in our Privacy Policy and applies solely to individuals who reside in the State of California (“consumers” or “you”).
We adopt this notice to comply with the CCPA and CPRA and to inform California residents about the personal information we collect, use, disclose, sell, and share, as well as their rights regarding that information.
1. Personal Information We Collect, Use, Disclose, Sell, or Share
Below is a table identifying the categories of personal information we may have collected from California residents within the last 12 months, whether we sell/share the information, and how we retain or disclose it. We also clarify categories we do not collect.
| Category | Examples | Collected | Sold | Shared for Cross-Context Behavioral Advertising | Disclosed for Business Purposes | Retention Period or Criteria |
|---|---|---|---|---|---|---|
| A. Identifiers | Name, email, phone, IP address, company name, postal code | Yes | Yes | Yes | Yes | Retained as long as necessary to fulfill lead delivery and legal obligations |
| B. Customer Records (Cal. Civ. Code §1798.80) | Same as above, overlaps with A | Yes | Yes | Yes | Yes | Same as above |
| C. Protected classification characteristics under CA or federal law | Age, gender, etc. | No | No | No | No | Not collected |
| D. Commercial Information | Product or service interests, quote history | Yes | Yes | Yes | Yes | Retained for internal analytics and client matching purposes |
| E. Biometric Information | Fingerprints, retina scans | No | No | No | No | Not collected |
| F. Internet/Network Activity | Device info, IP address, site interactions | Yes | No | Yes | Yes | Retained for analytics (typically 26 months via 3rd party tools) |
| G. Geolocation Data | Derived from IP address | Yes | No | No | No | Retained as above |
| H. Sensory Data | Audio, visual recordings | No | No | No | No | Not collected |
| I. Professional/Employment Info | Job title, employer | No | No | No | No | Not collected |
| J. Non-Public Education Info | School records under FERPA | No | No | No | No | Not collected |
| K. Inferences | Profiles from behavior or preferences | No | No | No | No | Not collected but may in future; if so, notice will be updated |
| L. Sensitive Personal Information (SPI) | Precise location, government ID, racial/ethnic data | No | No | No | No | Not collected and not used to infer characteristics |
2. Purposes for Collection and Use of Personal Information
We collect, use, and disclose personal information for the following business or commercial purposes:
3. Selling and Sharing of Personal Information
We sell personal information to our lead buyers (e.g., lenders, service providers) for the purpose of fulfilling your request for quotes or product information. We may also share personal information for cross-context behavioral advertising through platforms such as Meta and Google.
Categories of PI Sold: A, B, D
Categories of PI Shared for Advertising: A, B, D, F
You have the right to opt-out of both the sale and sharing of your personal information.
4. Right to Limit Use of Sensitive Personal Information
We do not collect or use Sensitive Personal Information (SPI) as defined in the CPRA. We do not use SPI to infer characteristics about consumers.
5. Retention of Personal Information
We retain personal information only as long as reasonably necessary to:
Retention periods may vary by data type and use case but are generally aligned with industry practices and platform storage standards (e.g., 26 months for analytics data).
6. Your Rights Under the CCPA/CPRA
As a California resident, you have the following rights:
You may make a request up to twice in a 12-month period. We will respond within 45 days.
7. How to Exercise Your Rights
To exercise your rights under the CCPA/CPRA:
We may require verification of your identity before processing your request. You may also designate an authorized agent to act on your behalf.
8. Contact Information
If you have any questions about this notice or our privacy practices, you may contact us:
Email: hello@scalesmartmarketing.com
Mailing Address: Compliance Manager, Level 22, 180 George St, Sydney NSW 2000
This notice was last updated on April 4, 2025.