Privacy Policy for California Consumers

As noted in our general Privacy Policy, Keyfactor, Inc. (“Keyfactor”) provides digital certificate issuance and management system services. At Keyfactor, the privacy and security of our customers and visitors are of paramount importance, and we are committed to protecting the data you share with us. Keyfactor recognizes and honors the fact that you, as a California Consumer, enjoy specific privacy rights regarding your Personal Information under both the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and related California legislation. The CCPA requires that we include a summary of your privacy rights in our Privacy Policy, so let’s start with a few important definitions. According to the CCPA, the term:

• “Consumer” means residents—i.e., every individual who is in the State of California for other than a temporary or transitory purpose as well as every individual who is domiciled in the State but who is outside the State for a temporary or transitory purpose.
• “Personal Information” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonable be linked, directly or indirectly, with a particular Consumer or household.”
• “Sale” means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration.”

As a California Consumer, you have the right:

• To opt out of the sale of your Personal Information.
• To know which Personal Information we collect about you.
• To know whether and to whom your Personal Information is sold/disclosed.
• To access the Personal Information that we have collected about you.
• To request that we delete your Personal Information (unless we are legally exempt from doing so).
• To not be discriminated against because you have exercised your CCPA rights.

It’s important to keep in mind that the CCPA provides a laundry list of information that would fall under the definition of Personal Information. You will find more about that in the paragraphs that follow, so read on for more information about your rights under the CCPA.

If you, as a California consumer wish to opt out of Keyfactor’s sale of your Personal information, simply click the following link: Do Not Sell My Personal Information. Once Keyfactor receives your request, we will cease to sell Personal Information that we collect about you. We will also respect your “opt-out” decision for at least twelve (12) months before we request authorization to sell your Personal Information again.

If you, wish to exercise additional rights under the CCPA regarding your Personal Information (e.g., right to access, right to deletion, etc.), you will need to submit a verifiable consumer request to Keyfactor by either:

• Completing the form at this link California Consumer Access Request; or
• Emailing us at [email protected].

Please keep in mind that only you, or a person who is registered with the California Secretary of State and authorized to act on your behalf, may submit a verifiable consumer request to Keyfactor related to your Personal Information. In the unlikely event that Keyfactor has collected, used, stored, sold, transferred or disclosed Personal Information about your minor child, you may also submit a verifiable consumer request on behalf of your child. You may only submit verifiable consumer requests for access to and/or data portability of Personal Information to Keyfactor about yourself or on behalf of another individual twice within a given twelve (12) month period. Your request must:

• Provide sufficient information to enable Keyfactor to reasonably verify that you are either the person about whom we have collected Personal Information or an authorized representative of that person.
• Describe the substance of the request with sufficient detail to empower Keyfactor to properly comprehend, evaluate and respond to it.

Remember: Keyfactor can neither adequately respond to your request nor provide the Personal Information at issue unless we can verify that you are the individual whose Personal Information rests in Keyfactor’s possession or that you are authorized to access such Personal Information.

You will not be required to create an account with Keyfactor to submit a verifiable consumer access request.

Keyfactor will solely utilize the Personal Information that you provide to submit a verifiable consumer request to confirm your identity as the requestor as well as your authority to make the request.

As a California consumer, you have the right to request free access to the Personal Information that Keyfactor collects, uses, “sells,” stores and/or discloses about you twice per year. That right extends to all Personal Information that we have collected, used, sold, stored and/or disclosed about you for the preceding twelve (12) months.

Keyfactor will normally provide access to your Personal Information in a portable and easily accessible format within forty-five (45) days of the company’s receipt of your request. We will notify you ahead of the expiration of that forty-five-day period should we discover that we will require additional time to fulfill your request or that we will be unable to do so. Keyfactor will include a written explanation of the delay in providing and/or inability to produce your Personal Information along with the notification.

Keyfactor will provide the following information in response to your request for access, if applicable:

• The categories of Personal Information that Keyfactor has collected about you
• The categories of sources of your Personal Information
• The business or commercial purpose for which Keyfactor collects and/or sells your Personal Information
• The categories of third parties with whom Keyfactor shares your Personal Information
• The specific pieces of Personal Information Keyfactor has collected about you

Keyfactor understands that you, as a California Consumer, have the right to request that we delete the Personal Information that we hold about you. It’s important to keep in mind, however, that your deletion rights do not override Keyfactor’s need to retain Personal Information that enables us to perform any of the following business-related tasks:

• Provide goods or services to you
• Detect or resolve security or functionality-related issues
• Comply with the law
• Conduct research in the public interest
• Safeguard the right to free speech
• Carry out any actions for internal purposes that you might reasonably expect

Keyfactor will honor your right, as a California consumer, to be protected from discrimination on the basis of your exercise of existing privacy rights under the California Consumer Privacy Act. Except as permitted under the CCPA, therefore, we will not take any of the actions listed below following your exercise of such rights:

• Deny goods or services to which you are entitled
• Charge you different prices for the goods or services we provide, whether by denying applicable benefits, granting discounts to those consumers who have not exercised such rights or imposing unwarranted penalties
• Provide a different level or quality of goods or services to you
• Threaten you with any of the actions above

Keyfactor reserves the right to offer you certain financial incentives that are permitted by the CCPA. Such incentives might culminate in different prices, rates or quality levels. Should we offer financial incentives to you, they will be reasonably related to the value of your Personal Information and will include descriptions of the program’s material components. We will obtain your opt-in consent to participation in a financial incentive program before we proceed, and you will maintain the ability to revoke such consent at any time.

Please read on for more information about the types of Personal Information that Keyfactor collects, sells and/or discloses.

Keyfactor acknowledges that it processes Personal Information in various ways described in the CCPA and that you have the right to request access to such information. We further recognize that you are entitled to exercise your rights under the CCPA as to Personal Information we have collected, sold and/or disclosed about you during the twelve (12) months immediately preceding our receipt of your request. In light of the foregoing, we have provided an overview of the Personal Information that Keyfactor processes in the sections that follow.

Keyfactor uses the Personal Information it collects to facilitate communication with consumers who are new or returning visitors its website, to customize content for such consumers, to display ads on other websites of interest to consumers, and to improve the website by analyzing how such consumers navigate the website. Keyfactor also collects Personal Information from consumers who possess established, user-based relationships with the company. We do so in order to enhance our ability to identify returning users, provide such consumers with support, services, mailings, sales and marketing materials and billing information and to foster our ability to meet various contractual obligations. Keyfactor has collected Personal Information about consumers in the categories marked “Yes” below in the preceding twelve (12) months:

Keyfactor collects Personal Information about consumers in the categories below from the sources listed and for the commercial or business purposes indicated:

Keyfactor has sold Personal Information about consumers in the categories marked “Yes” below in the preceding twelve (12) months:

Keyfactor engages trusted service providers to perform various functions and provide a myriad of services to us. Such services include, but are not necessarily limited to, the following: hosting and maintenance; error monitoring; debugging; performance monitoring; billing; customer relationship; database storage and management; and direct marketing campaigns. In light of the foregoing, Keyfactor may share your Personal Information with such service providers but will limit such disclosures to the extent necessary to perform the specified functions and provide such services. Keyfactor also requires its service providers to maintain the privacy and security of the Personal Information that they process on our behalf.

Keyfactor has disclosed the following categories of Personal Information about consumers for the business purposes described below in the preceding twelve (12) months:

• Tailored advertising partners
• Affiliates

Keyfactor sells the following categories of Personal Information about consumers to third parties:

• Social network information. When you use a social network to access our services, you will share certain Personal Information from your social media account with us. Such Personal Information may include, for example, your name, email address, photo, list of social media contacts, and any other information which may be or that you may make accessible to us when you connect your social media account to your services account. The specific information transferred will depend upon your security settings and the privacy policy of your social media network.
• Joint marketing partners when they share information with us.
• Publicly available databases.

• To fulfill the purpose for which you provided the Personal Information. If, for example, you share your name and contact information with us in order to request a price quote or ask a question about our products or services, we will utilize that Personal Information to respond to your inquiry. If you provide Personal Information in order to purchase a product or service, we will also use such information to process your payment and facilitate delivery. Keyfactor may also save your Personal Information in order to facilitate new product orders or process returns.
• To provide, support, personalize and/or develop our Websites, products and/or services.
• To create, maintain, customize and secure your account with us.
• To process your requests, purchases, transactions and payments and to prevent transactional fraud.
• To provide support to you and to facilitate our ability to respond to your inquiries—including the capacity to investigate and address your concerns and monitor and improve our responses.

Keyfactor assumes that all California Consumers who visit the company’s site or utilize its platforms have carefully read this document and have agreed to its contents. If you do not agree with the provisions of this Privacy Policy, please refrain from using our website and platform. We reserve the right to change our Keyfactor Privacy Policy for California Consumers as necessity dictates. Should you continue to use the Keyfactor website and platform after having been informed of any changes to these provisions, Keyfactor will deem such ongoing use an implied acceptance of its revised Privacy Policy. This Privacy Policy is an integral part of Keyfactor’s terms of use for California Consumers.

Keyfactor reserves the right to reveal a California Consumer’s Personal Information to a third party without his/her/their prior permission when the company has reason to believe that it must disclose the information in order to:

• Establish the identity of, to contact, or to initiate legal proceedings against a person or persons who are suspected of infringing Keyfactor’s intellectual property rights in the company’s products or services; or
• To protect the interests of others who could be harmed by the California Consumer’s activities or in instances in which entities or persons might (whether willfully or negligently) violate another party’s interests in rights and/or property.

Keyfactor reserves the right to disclose Personal Information to third parties when necessary to comply with legal or regulatory obligations and/or law enforcement requests.

Keyfactor limits access to your Personal Information to those employees and consultants who require access to such information in order to perform their jobs and provide products or services to you. Keyfactor maintains physical, electronic, and procedural safeguards that are designed to comply with industry standards surrounding the protection of your Personal Information.

As Keyfactor collects Personal Information about California Consumers for processing purposes, we reserve the right to contract with vendors who can assist us with such processing. Keyfactor requires that such vendors maintain the confidentiality of the Personal Information entrusted to them for processing and that they refrain from using such data for any purpose other than supporting Keyfactor’s provision of services to its customers.

Keyfactor’s services are solely meant to be purchased and used by those over the age of 18. We neither target provision of our services to individuals below the age of 18 nor do we intend that such services be consumed by or designed to attract the attention of such individuals. If you know or have reason to believe that any individuals under the age of 18 have shared their Personal Information or Personal Data with Keyfactor, please contact us using the methods described in section 3 of this Privacy Policy.

California Consumers may submit requests to Keyfactor in order to obtain access to or deletion of their Personal information by contacting us as described in sections 3 of this Privacy Policy. If you submit such a request to Keyfactor, and we discover that we require the Personal Information at issue in order to provide the products or services you have purchased, Keyfactor will honor the request to the extent required by applicable laws and regulations. As part of that assessment, we will determine the extent to which: our access and/or processing of the Personal Information may be necessary to provide the services purchased; we may require ongoing access to such information for legitimate business purposes; and/or we may be compelled to maintain such information because of legal, regulatory or contractual recordkeeping requirements or other obligations. You may still choose to opt out of the sale of your Personal Information to third parties.

We reserve the right to modify this Keyfactor Privacy Policy for California Consumers at any time. If we decide to change our Privacy Policy, we will post those changes to this site as well as any other sites, links or resource materials Keyfactor deems appropriate. We are committed to ensuring that you are aware of the information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page at least thirty (30) days prior to our implementation of such changes. Keyfactor reserves the right to update its Privacy Policy on a more expedited basis as necessary to comply with applicable legal and regulatory bodies’ implementation of new and/or amended laws and regulations.

Keyfactor maintains a “Data Protection Officer” who is responsible for all matters related to privacy and data protection. You can reach our Data Protection Officer at the following address:

Keyfactor, Inc.

Attn: Data Protection Officer

6150 Oak Tree Boulevard, Suite 200

Independence, OH 44131

+1.216.785.2990

[email protected]

If you have any further questions regarding the data Keyfactor collects, or how we use it, please contact us in writing at:

Keyfactor, Inc.

6150 Oak Tree Boulevard, Suite 200

Independence, OH 44131

[email protected]