CCPA

For California Residents

If you are a resident of California, this notice applies to you and supplements the Rocketbook Privacy Policy. This notice is intended to provide certain information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”). 

This notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your 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 (“personal information”). Personal information does not include de-identified, aggregated or anonymized information, publicly-available information, and certain other information that is regulated by other applicable laws such as the Gramm-Leach-Bliley Act.

Your Rights

Right to Know 

You have the right to request that we disclose certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected about you
• The categories of sources from which we have collected your personal information
• Our business or commercial purpose(s) for collecting or selling your personal information 
• The categories of third parties with whom we have shared your personal information; and 
• The specific pieces of personal information we have collected about you

You have the right to request that we disclose certain information to you about our disclosures and sales of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following: 

• The categories of personal information we have collected from you
• The categories of personal information we have sold about you and the categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose

Right to Opt-Out 

We do not sell your personal information now and have no plans to start, however, we are required to let you know that you have the right to opt-out of the sale of your personal information at any time if we ever engage in such activity. Additionally, we use third party cookies and similar technologies for targeted advertising purposes. To opt-out of having your information shared with third-party digital advertising vendors for this purpose, please contact us as described in the “How to Contact us to Exercise Your Rights” section below. 

Right to Delete

You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws. 

Right to Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different service level to you. However, we may charge a different price or provide a different service level only if the price or difference is directly related to the value provided to you by your personal information. 

How to Contact us to Exercise Your Rights

To submit a request to exercise your “Right to Know” or “Right to Delete” rights provided in this notice, please email us at be legal@rocketbook.com, or submit your request by phone by calling us toll-free at (888) 275-5436. We will evaluate the request and take action where required to do so

We will confirm receipt of your request within 10 business days and will provide information about how we will process your request. We endeavor to respond to your request as soon as we can, within the timeframes permitted under the CCPA. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

Verification of Requests and Authorized Agents

We may have to verify your identity when you contact us to exercise your “Right to Know” or your “Right to Delete.” Our verification process may vary depending on the nature of your request. However, generally, we will verify your request by asking you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent to make a request on your behalf, unless you have provided the authorized agent with power of attorney, we may require that: (1) you provide your authorized agent signed permission to do so; (2) you verify your identity; and (3) you confirm that you have provided the authorized agent permission to submit the request. We may deny any request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf

Your authorized agent may make a request on your behalf by contacting us at legal@rocketbook.com.

Please note that in most cases we are not able to respond to more than two “Right to Know” requests from a consumer in any 12-month period.

Information We Collect

We have collected the following categories of personal information from consumers in the last twelve (12) months:

Identifiers (such as email address, first name and last name, mailing address, phone number, date of birth, IP addresses, device identifiers, and account information)

Personal information as defined in the California customer records law (such as name, contact information, date of birth, and education)

Commercial information (such as products or services you considered, transaction information, purchase history, financial details and payment information)

Internet or other electronic network activity (such as your browser type, frequency and time and date of visits to our Site, operating system, the site from which you linked to us, the name of the website you chose to visit immediately after ours, information about other websites you have recently visited, site activity, and information about and from your device, including but not limited to device ID, device language, and operating system) 

Geolocation data (such as your approximate location based on IP address)

Professional or employment-related information (such as your employment status and job type)

Inferences from the above information (we may draw inferences drawn from any of the information identified above to create profiles of users and those that interact with us)

For additional examples of the types of information that we may collect, please see the “Information Collected” section of the Rocketbook Privacy Policy. 

Our sources for this information:

We collect personal information that you voluntarily provide to us when you use our Site, download and use our mobile application, purchase our products or services, when you participate in one of our crowdfunding campaigns, our events, or when you interact with us. 

When you visit our Site, certain personal information is automatically collected from you, your browser, or your device.

Our business purposes for collecting this information: 

We generally use personal information for the purposes for which we collect it. The specific personal information we collect, and how we use that information, will depend on the nature of our relationship with you. We collect personal information so that we can provide our products and services to you, provide information that you request from us, and operate our business. This includes responding to inquiries and questions, communicating with you, creating and administering your account, fulfilling orders for our products, send you updates about our company and our products and services. 

We may also use personal information to: (i) analyze, operate and improve the Site, our Services, and our business; (ii) customize the content you see when you use the Site, or the Services that we offer to you; (iii) conduct market analysis, research, traffic flow analysis and related reporting to third parties; and (iv) for any other purposes disclosed to you at the time we collect your personal information.

We may also use personal information as we believe may be necessary or appropriate for certain essential purposes, such as: (i) to comply with applicable law and legal process; (ii) to respond to requests from public and governing authorities; (iii) to detect, prevent, or investigate potential security incidents or fraud; (iv) to enforce our Terms of Service or any other contract; (v) to protect our operations or those of our affiliates; (vi) to protect our rights, privacy, safety or property, security and/or that of third parties; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain. 

Third parties we share this information with: 

We share your personal information with our third-party service providers who provide services such as website hosting, data analysis, analytics, marketing, IT services, email delivery services, and other services, to enable them to provide services. These third party service providers are not authorized to retain, share, store or use the personal information for any purposes other than to provide the services they have been hired to provide. If you use certain features in our Services, we also share your information and your scans with third party cloud storage providers as directed by you. Additionally, as discussed above, we may share your personal information with third party digital advertising vendors for targeted advertising purposes. 

We may share personal information as necessary for the essential purposes described in our Privacy Policy and in other contexts with your consent. Your personal information may also be disclosed to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, or assets (including in connection with any bankruptcy or similar proceedings).

We may also transfer personal information to third parties under the following circumstances: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Rocketbook; (iv) when we believe it is necessary to protect the rights, property, or safety of Rocketbook or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of Rocketbook.

Financial Incentives

We may offer financial incentives, including discounts as compensation, for the collection of personal information (such as when you provide certain personal information to us in order to receive a discount on your next order from us). Other financial incentives may include offering a different price, rate, level, or quality of goods or services to you if that price or difference is directly related to the value provided to you by the personal information. We will notify you of incentives when offered and will only enter you into a financial incentive program if you opt-in. You may revoke your opt-in consent at any time. In determining the value of your personal information to us, we consider the value generated from providing a more personalized marketing experience that is based on personal information, which is reasonably correlated to the value provided to you through the incentives that we offer.

Last Modified: November 2, 2020

Click Here for Printable Version

103565995v.1