California Consumer Privacy Act (CCPA): About CCPA and Your Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights respecting the collection, use, and disclosure of their personal information. To the extent applicable to Spearmint Ventures, LLC (“Spearmint”), this notice is intended to comply with the CCPA and other applicable laws and may apply to you in addition to our Privacy Policy. This information and the rights discussed below do not apply to information collected from or about our employees, former employees, candidates, contractors, service providers, or business contacts.

Spearmint collects information that identifies, relates to, describes, references, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or device. Set forth in detail below are the categories of information that Spearmint may collected about you and the methods of collection.

Collection and Disclosure During the previous twelve months, we may have:

A. Collected the following categories of personal information about you, whether via the website ("Site") or direct customer interaction:

Identifiers. By way of example, a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Identifiers (Online). By way of example, cookies, pixel tags, beacons, and similar technology, a device identifier, other forms of persistent or probabilistic identifiers and Internet Protocol address.

Personal Information Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). By way of example, 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. Some personal information included in this category may overlap with other categories.

Commercial Information. By way of example, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

Internet or other similar network activity. By way of example, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Geolocation data. By way of example, physical location or movements reported by your device.

Profile Inferences. By way of example, inferences from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

B. Collected personal information about you for the following business or commercial purposes:

  • To audit related to a current interaction with you and concurrent transactions (such as counting ad impressions and verifying position and quality of ad impressions)
  • To provide products and perform services you have purchased from or contracted from us such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing or assist with providing financing, providing advertising or marketing services, providing analytic services, or providing similar services
  • To detect security incidents, fight spam, protect against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
  • To further develop and improve our Site and present its contents to you including, but not limited to, debugging errors that impair the Site’s functionality and personalize user experience
  • To monitor and analyze trends and better understand how users interact with our content, which helps us improve our content, and other research
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention
  • To permit short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • To communicate with you from time to time in response to your requests for information or as may be relevant to your account with us
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections
  • To comply with and enforce applicable legal requirements, relevant industry standards, and our policies
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred
  • As described to you when collecting your personal information or as otherwise set forth in the California Consumer Privacy Act and in our Privacy Policy

C. Obtained the categories of personal information identified above from the following categories of sources:

  • Directly from our customers, their agents, or other visitors to the Site from information they provide related to our products or services for which they engage Spearmint including through the Site or via telephone or written correspondence
  • Directly from our customers or visitors to the Site through information we ask from them including through contact forms, e-mail marketing campaigns, and our social media features
  • Directly and indirectly from our customers or visitors to the Site when using our products or services or visiting our Site such as usage details collected automatically in the course of their interaction with our platform or Site
  • From third parties that interact with Spearmint in connection with the products or services we provide

D. Shared your personal information with the following categories of third parties:

  • Our vendors (e.g., our credit card processing company)
  • Third parties to whom you or your agents authorized us to disclose our personal information in connection with the products and services Spearmint provides
  • Third party advertising affiliates, to the extent that they collected such personal information
  • Social media networks, to the extent that they collected such personal information

E. Sold (as defined by California law) the following categories of personal information:

  • Identifiers (online) associated with a device used to interact with our digital properties or advertisements (such as a device identifier, cookies, beacons, pixel tags, mobile ad identifiers and similar technology)
  • Internet and other electronic network activity information associated with a device used to interact with our digital properties or advertisements

We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.

We do not sell personal information as the term is traditionally understood, versus the definition under the CCPA. For instance, we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us. 

Except as indicated above under the definition of a sale under the CCPA, in the last 12 months, Spearmint has not sold any personal information.

F.      Disclosed for a business purpose the following categories of personal information about you: 

  • Identifiers
  • Identifiers (Online)
  • Personal Information Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
  • Commercial Information
  • Internet and Other Electronic Network Activity Information
  • Geolocation Data
  • Profile Inferences

Your Rights and Choices under the CCPA

Access to Specific Information Collected or Used by Spearmint

You have the right to request, twice in a 12-month period, that we disclose to you the personal information related to you we have collected during the past 12 months. This may include the following:

  • The categories and specific pieces of personal information we collected about you
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom we shared that personal information
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • o Sales, identifying the personal information categories that each category of recipient purchased; and 
  • o Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained

Deletion of Personal Information

You have the right to request that we delete certain personal information that we collected from you and retained. Once we receive and confirm your verifiable personal information request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Exceptions may include any of the following:

  • 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
  • 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 of free speech
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
  • Enable solely internal uses that are reasonably aligned with the consumer’s expectations based on your relationship with us
  • Comply with a legal obligation
  • Otherwise undertake internal uses in a lawful manner that are compatible with the contract in which the consumer provided the information

Opt-Out of Sale

The CCPA broadly defines “sale” in a way that may also include the delivery of targeted advertising on the Site or other sites, including allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior.

Accordingly, while Spearmint does not sell your personal information in the traditional sense, we have provided you with the ability to opt-out of the “sale”, as defined by the CCPA, of your personal information.

How to Submit a Request

Submit an access request or call us at ‪(480) 712-3566‬ to request that Spearmint disclose your personal information that we collected or used

Submit a deletion request or call us at ‪(480) 712-3566‬ to request that Spearmint delete your personal information

More information on opting out of the sale of your personal information is available here

Verifying The Request

You have the right to request the above information twice in a 12-month period at no charge to you. The verifiable consumer request must:

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

You are not required to create an account in order to make this request. We will only use the personal information provided in a verification consumer request to verify the requestor’s identify or authority to make the request.

Response to Requests for Access and Deletion of Personal Information

After we receive and confirm your verifiable personal information request, we will provide you with a copy of the requested information via email or postal mail or through your account with Spearmint within 45 days from your request. When reasonably necessary, we may notify you of a 45-day extension to fulfill your request.

Additional Information

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

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