CALIFORNIA CONSUMER PRIVACY ACT
1. VoilaNorbert Services
The Services allow VoilaNorbert’s business customers (“Customer” or “Customers”) to perform email address lookup and verification and data enrichment on sets of emails. Customers can access these services through manual entry, uploading a csv file or using our APIs.
2. Information We Collect About You and How We Collect It
We collect several types of information from and about Visitors of our Website, including information:
- by which you may be personally identified, such as name, e-mail address, telephone number, company name, company address and billing information (“personal information“); and/or
- about your internet connection and usage details.
We collect this information:
- Directly from you when you provide it to us; and
- Automatically as you navigate through the site. Information collected automatically may include usage details (such as your activity on our Website), session data such as IP addresses and web browser software.
3. Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you voluntarily provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or subscribing to our service. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- To provide the Services, VoilaNorbert receives and stores your personal information (“Customer Data”).
4. How we use your information
VoilaNorbert uses the information that we collect about you or that you provide to us, including any personal information for a variety of purposes including:
- To provide the Services.
- To present our Website and its contents to you.
- To communicate with you about your account and the Services.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To troubleshoot any issues with the Website or Services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- For any other purpose with your consent.
VoilaNorbert processes your personal information for the purposes identified above and the legal basis for VoilaNorbert processing this information is as follows: (i) in order to provide our Services to you, (ii) for the performance of a contract between you and us, (iii) our legitimate interests, including the proper administration of our website and business, (iv) to protect your vital interests, or (v) your consent, which you may withdraw at any time.
5. When VoilaNorbert discloses your information
General. VoilaNorbert does not provide your personal information or any other information you provide to VoilaNorbert to any unaffiliated third parties.
Third Parties. VoilaNorbert may provide your personal information or any other information you provide to VoilaNorbert to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
Legal Requests and Comply with State and Federal Laws. VoilaNorbert may release personal information or other information provided by you if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws or to respond to a court order, subpoena, or search warrant. VoilaNorbert also reserves the right to disclose personal information or other information that VoilaNorbert believes, in good faith, is appropriate or necessary to enforce VoilaNorbert’s Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Website or Services, and to protect the rights, property, or personal safety of VoilaNorbert, its Customers or others.
In the Event of Merger, Sale, or Bankruptcy. In the event that VoilaNorbert is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal or non-personal information is treated, transferred, or used.
6. Personal Information Categories Listed in the California Customer Records Statute
- Business email
- Publicly available information.
- First-hand research.
- Submissions from VoilaNorbert’s customers or freemium product users.
- Third-party data vendors.
- Directly and indirectly from activity on VoilaNorbert’s website.
- Directly and indirectly from our customers or their representatives.
- Directly from vendors and other contractual counterparties.
- Through communication with prospective customers and other businesses and their representatives.
7. Disclosure or Sale of Personal Information and the Right to Opt-Out
We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to VoilaNorbert’s customers for the purpose of business-to-business sales and marketing and recruiting and is provided subject to license agreements that limit its use to those purposes.
A consumer has the right to opt out of the sale of that consumer’s personal information by VoilaNorbert by submitting a request to remove the consumer’s profile or delete the consumer’s data at email@example.com. In order to submit a request, a consumer or an authorized agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.
For avoidance of doubt, the personal information disclosed and/or sold by VoilaNorbert within the identified categories is limited to business contact information related to a consumer’s profile as an employee of its employer. No sensitive personal information (i.e. Social Security number, passport number, medical or financial information) is collected, shared, disclosed, or sold by VoilaNorbert.
We do not sell the personal information of minors under 16 years of age.
8. CCPA Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.
– Access to Specific Information and Data Portability Rights
A consumer has the right to request that we disclose certain information to that consumer about VoilaNorbert’s collection and use of that consumer’s personal information over the past 12 months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:
- The categories of personal information we collected about that consumer.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about that consumer (also called a data portability request).
– Deletion Request Rights
A consumer has the right to request that VoilaNorbert delete any of its personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.
We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:
- Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
- 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 (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if a consumer previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.
– Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contact us at firstname.lastname@example.org.
Only a consumer or a person registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.
A consumer 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 VoilaNorbert to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
- Describe a consumer’s request with sufficient detail that allows VoilaNorbert to properly understand, evaluate, and respond to it.
We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
– 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 the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. 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. For data portability requests, we will select a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.
We will not discriminate against a consumer for exercising any CCPA rights.
– Changes to Our Privacy Statement
We reserve the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will provide notification by email or through a notice on our website homepage.
9. Contact Information
1920 E. Riverside Drive
Austin, TX 78741