Effective Date: August 27, 2021
Last Reviewed on: August 27, 2021
If you are a California resident, California law provides you with additional rights regarding our use of your personal information. This Privacy Notice for California Residents applies only to personal information (defined below) concerning individuals who reside in the State of California. Maestro LLC (“Maestro” or “we” or “us”) provides this notice in accordance with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), or clinical trial data.
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from or about consumers within the last twelve (12) months:
|A. Identifiers.||First name, last name, Internet Protocol address, email address, account name, company name, job title, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||First name, last name, Internet Protocol address, email address, account name, company name, business postal address, job title, or other similar identifiers.||Yes|
|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).||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|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.||No|
|F. Internet or other similar network activity.||Information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes|
|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.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from surveys and forms you complete or through your direct commercial, business, or current or prospective employment relationship with us.
- Indirectly from you. For example, from observing your actions on our Site, from your use of any other websites affiliated with Maestro or from information you post on or submit to our Site.
- From other sources. For example, third-party marketing companies that we use to provide you with information concerning our products, service offerings, and other information.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To Further an Established Business Relationship. We use collected information to serve established business relationships that we have developed with you, including providing products and services to you in connection with our established business relationship, providing you with notices about accounts or subscriptions you maintain in connection with one or more of the Sites, including expiration and renewal notices, and to carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection. We may also contact you to ask for your feedback about a product, service, or event.
- To Send You Promotional Materials. We may also use your information to fulfill your requests, including, but not limited to, requests to receive promotional materials. Promotional materials may include newsletters or other information regarding Maestro contests, events, and/or products. We may also use your information to share other services or products that may be of interest to you. Promotional materials may be conveyed in emails. If you no longer wish to receive these materials, you may opt out by following the opt-out instructions included in our emails, texts, or mailings, or by contacting us at email@example.com.
- To Improve Our Services. As described above, we may collect information using Cookies, tracking tools, and/or analytic tools. We may use this information to personalize your experience on the Site or with the company and/or to improve the security, design, and/or function of the Site. We may also use your information to support and develop our products and service offerings.
- To Fulfill or Meet the Reason you Provided the Information. For example, if you share your name and contact information to request information or ask a question about our products or service offerings, we will use that information to respond to your inquiry. We may also save and use your information to market or promote our products and service offerings.
- To Provide Customer Support. We may use your information to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To Maintain Safety and Security. We may use your information to help maintain the safety, security, and integrity of our products, websites and services, databases, and other technology assets, and business.
- To Further Product Development. We may use your information for testing, research, analysis, and product development to allow us to develop and improve our products and service offerings.
- To Comply with Our Legal Obligations. We may use your information if we are required to respond to a law enforcement request and as required by applicable law, court order, or governmental regulations.
- To Communicate Employment Opportunities or Decisions. If you are a candidate for employment at Maestro, we use your information to make decisions on your potential employment, including contacting you for additional information, informing you of any employment decisions, or informing you of additional employment opportunities.
- Other uses:
- To present our Site and its content to you.
- To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide through it.
- As described to you separately when collecting your personal information or under the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- With Software/IT and cloud service providers we use to support our business.
- Data analytics provider.
- Web hosting services.
- Business communication and collaboration tool.
- Sales and marketing tools.
- Job applicant tracking system.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Maestro has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Sales of Personal Information
In the preceding twelve (12) months, Maestro has not sold personal information nor has it sold personal information of Minors under the age of 16.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
1. Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the 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 share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
2. Deletion Request Rights
You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:
- 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 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 et. 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 you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your 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 you provided it.
3. 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:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us through the methods noted above. Only the consumer or authorized agent may make a verifiable consumer request related to their personal information. An “authorized agent” is a person (or a business entity registered with the California Secretary of State) that consumers have authorized to act on their behalf or an individual granted authority under a written power of attorney issued pursuant to California Probate Code sections 4000 to 4465.
If you are an authorized agent who wishes to submit a request to know, a request to delete, or a request to opt-out on behalf of another consumer, please submit to us sufficient information to allow us to verify your identity to a reasonably high degree of certainty and either:
- Proof of authorization to submit the request, written and signed by the consumer; or
- A power of attorney pursuant to Probate Code sections 4000 to 4465.
We may deny a request from an authorized agent who does not submit adequate proof that they have been authorized by the consumer to act on the consumer’s behalf. We may also contact the consumer directly to confirm their identity and that they provided you permission to submit the request on the consumer’s behalf.
You 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 us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- 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 the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
4. Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable request. 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 your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Do Not Track Disclosure
Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. We do not currently recognize or respond to DNT signals. For more information about DNT, please see www.eff.org/issues/do-not-track.
California Shine the Light
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
California Business and Professions Code Section 22581
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, please send a detailed description of the specific content or information you wish to have removed; see Contact Us below. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you have any questions or comments about this notice, the ways in which Maestro collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
- Visiting maestrolearning.com/ccpa
Postal Address: 261 E. Kalamazoo Ave, Suite 401, Kalamazoo, MI 49007