In this Supplemental California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”), we, Sauce Labs Inc., disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”) and supplement the disclosures in our other privacy notices. This CCPA Privacy Policy is effective January 1, 2020.
I. Who and what information is subject to this CCPA Privacy Policy?
California residents are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA. As a result, this CCPA Privacy Policy does not apply to the following:
personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency
personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business
personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file
personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. How can an individual with a disability access this CCPA Privacy Policy?
Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this document.
III. Supplemental CCPA Disclosures
We provide additional disclosures about consumer rights and our personal information handling practices in the preceding twelve months, as required by the CCPA and regulations of the California Attorney General, including § 999.308 (Privacy Policy).
1. Right to Know About Personal Information Collected, Disclosed, or Sold
We describe here the personal information that we generally collect, use, disclose and sell about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please visit our privacy request webform. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
We will ask that you provide certain information to verify your identity, specifically, a confirmation link sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
2. Our Personal Information Handling Practices in 2019
We have set out below the categories of personal information we have collected about California residents in the preceding 12 months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.
Category of personal information: | We collected such personal information for the following purposes: | We collected such personal information from the following categories of sources: | We shared such personal information with the following categories of third parties: |
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | To communicate with you in relation to your account; to: (i) create an account for you in our service; (ii) manage the account; (iii) fulfill your orders for our products and services; and (iv) provide you with customer service and technical assistance;to respond to any specific comments or questions you may have;,to (i) provide, maintain, monitor, secure, debug, customize and optimize our products and services; and (ii) develop and improve our products and services;,to supplement the other personal information we hold about you in support of our sales and marketing activities; to manage and secure our events; to perform our obligations and exercise our rights under our Terms of Service or any other agreement relating to our products and services that you conclude with us; to perform activities necessary to ensure compliance with applicable national, state, provincial and other applicable laws, and to respond to requests from government authorities;,to protect the legal interests, health or safety of a user, us, or other third parties, such as in the event of a complaint or dispute, or to perform credit recovery procedures or credit assignments to authorized third parties;as permitted by applicable law, including with your consent where required, we may use your contact information to provide you with marketing communications, promotional offers and updates on new products and services; in the event that we, or some or all assets related to our business are acquired by or merged with a third-party entity or in connection with a merger, acquisition, sale, or other change of control, we may transfer some or all of the personal information that we have collected about you to another organization as part of that transaction. If we intend to transfer your personal information in connection with such a transaction, we may proceed with notice to you, grant you an opportunity to object, or seek your consent, as permitted or required by applicable law. | Directly from consumer. | Advertising networks, internet service providers, data analytics providers, operating systems and platforms, information technology service providers. |
Any categories of personal information described in subdivision (e) of Section 1798.80: “Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, address, telephone number, credit card number, debit card number, or any other financial information. | All purposes listed above. | Directly from consumer. | Advertising networks, internet service providers, data analytics providers, operating systems and platforms, information technology service providers. |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | All purposes listed above. | Directly from consumer. | Data analytics providers, information technology service providers. |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. | All purposes listed above. | Directly from consumer. | Advertising networks, internet service providers, data analytics providers, operating systems and platforms, information technology service providers. |
Geolocation data. | All purposes listed above. | Directly from consumer. | Data analytics providers, information technology service providers. |
Audio, electronic, visual, or similar information. | We store information electronically and use it for the purposes listed above. | Directly from consumer. | Advertising networks, internet service providers, data analytics providers, operating systems and platforms, information technology service providers. |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, or behavior. | To (i) provide, maintain, monitor, secure, debug, customize and optimize our products and services; and (ii) develop and improve our products and services. | Directly from consumer. | Data analytics providers, information technology service providers. |
3. Disclosures of Personal Information; No Sale
Over the preceding 12 months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above.
We do not and will not sell California residents’ personal information. We do not sell the personal information of minors under 16 years of age without affirmative authorization.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please visit our privacy request webform. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.
We will ask that you provide certain information to verify your identity, such as a code sent to an email address we may have on file for you. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
5. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. We do not, and will not, sell your personal information.
6. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code § 1798.125.
7. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in Sections 1 and 4 above:
Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to Sauce Labs Inc., 116 New Montgomery Street, Suite 300, San Francisco, California, Attn: Legal Department; and
Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
8. Contact for More Information
If you have questions or concerns regarding our privacy policy or practices, you may email us at privacy@sauce.labs.com.
