CCPA
Last Revised: November, 2020
Togo Networks Ltd. (the “Company“, “Togo Networks Ltd“, “We“, or “Our“) adopts this privacy notice (“Notice“) in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. This Notice provides the information contained in our privacy policy (“Privacy Policy“) and applies only to the State of California residents (“you” or “consumers”).
This Privacy Notice constitutes an integral part of our Privacy Policy, and therefore the definitions used in this Notice but not defined in the Notice or in the CCPA, shall have the meaning granted to them in the Privacy Policy. This Notice set out in detail how and why we collect and process your information. The CCPA provides Consumers with specific rights regarding their Personal Information.
For more information regarding your privacy rights and California privacy rights, please review our Privacy Policy and
https://oag.ca.gov/privacy/privacy-laws.
THE CATEGORIES OF INFORMATION COLLECTED BY TOGO NETWORKS LTD
The CCPA defined “Personal Information” as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device.
We collect (and have collected within the last 12 months) the following categories of Personal Information:
| CATEGORY | PURPOSE OF COLLECTION AND USE | COLLECTED |
| A. Identifiers. | A 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. | Collected |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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. | Not Collected |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Not Collected |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Collected |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Not Collected |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Collected |
| G. Geolocation data. | Physical location or movements. | Not Collected |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Not Collected |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Not Collected |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Not Collected |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Not Collected |
DISCLOSURES FOR BUISNESS PURPOSES
We have disclosed Personal Information to the following categories of third parties for business purpose:
- Service providers
- Business partners (for example, for payment calculation and fraud detection and to feed providers that implemented their feed as part of our services)
- Data aggregators (for example, for analytics purposes)
We have disclosed the following categories of Personal Information for business purpose:
- Category A: Identifiers;
- Category F: Internet or other similar network activity.
- Category D: Commercial information.
THE USES OF PERSONAL INFORMATION
We use the Personal Information we process for one or more of the following business purposes:
- To fulfill the reason for which we collect the information. For instance, if a Consumer contact us in order to ask a question, we will use its Personal Information, such as name and email address, in order to provide him with the answer to its question;
- To maintain and protect the Installer and Software from security and fraud attacks, and to ensure the integrity of our Installer and Software;
- To develop and enrich our services;
- As required under applicable and regulations;
- As detail in the Privacy Policy
We will not collect additional categories of personal information, and we will not use the Personal Information for unrelated or materially inconsistent purposes without giving previous notice.
SALE OF PERSONAL INFORMATION
Togo Networks Ltd has not sold Personal Information in the preceding twelve (12) months
RIGHTS & CONTROLS
If you wish to exercise your rights regarding your Personal Information, please fill out the Privacy Rights Request Form available here, and send it to Togo Networks Ltd’s privacy team at: support@togonetworksltd.com
CONTACT US
For further information regarding this Policy or any privacy issues, please contact us at:
Togo Networks Ltd
support@togonetworksltd.com