California Privacy Policy

Last Updated: January 1, 2020

This California Privacy Policy (as it applies to California Consumers) explains:

1. How we collect the personal information of California consumers
2. How we share the personal information of California consumers
3. Your California Privacy Rights
4. How to exercise Your California Privacy Rights

Scope:

PubNub Inc., its subsidiaries, affiliates, and its group of companies, (“Company”, “we”, “us” and “our”) takes your privacy seriously. We want you to know how we collect, use, share, and protect your personal data. This California Privacy Policy only applies to the personal information of California residents in their capacity as consumers (“California consumers”). This California Privacy Policy supplements PubNub’s Privacy Policy and applies to all personal information of California consumers collected, disclosed for business purposes, or sold by Company, regardless of whether the personal information is collected, disclosed or sold through Company’s website in the preceding 12 months.

1. How We Collect the Personal Information of California consumers

   For purposes of this California Privacy Policy, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

   Categories of Personal Information Collected In The Last 12 Months (as specified by California Statue)	Sources of That Personal Information	Business Purposes And Commercial Purposes For Collecting That Personal Information
   Category A: Categories described in Cal. Civ. Code § 1798.80(o)(1) list Personal Information or Identifiers, including: real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or similar identifiers	The California consumer or automated technologies in the website	To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.
   Category B: Personal information listed in Cal. Civ. Code § 1798.80(e) such as name, signature, telephone number, education, billing and transaction information.	The California consumer or Automated technologies in the website		To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.
   Category D: Commercial information, including: products and services purchased, or usage history.	Automated technologies in the website		To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.
   Category F: Internet or other electronic network activity information, including: consumer’s interaction with the PubNub website or services, browsing history.	Automated technologies in the website		To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.
   Category G: Geolocation data, such as approximate physical location derived from an Internet Protocol address.	Automated technologies in the website or provided by the California consumer		To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.
   Category I: Professional, or employment-related information including: education, job title, and employer name.	The California consumer or from our partners or third parties		To provide the services, including maintaining or servicing accounts, authorizing access to our service, verifying customer information, processing or fulfilling orders and transactions, billing, processing payments, and providing customer support. To personalize your experience by providing advertising or marketing services, to promote and drive engagement with the Services. To communicate with you about the Services, transactional communications, special events, promotions, surveys, and respond to questions and feedback. To audit a current interaction with the consumer and concurrent transactions. For safety and security, to detect security incidents, or protect against abuse, malicious, deceptive, fraudulent, or illegal activity. To debug, identify and repair errors that impair existing intended functionality. For short-term, transient use. For internal research and technological development. To verify or maintain the quality of the service, and to improve, upgrade, or enhance the service. By providing training and information on using, servicing, and displaying Company’s products and services. To protect the Company’s legitimate business interests and legal rights as required by applicable law, regulation, legal process, compliance functions, or in connection with the acquisition, merger or sale of a business.

2. How We Share The Personal Information Of California consumers

   Sale of Personal Information: For the purposes of CCPA, in the last 12 months, the Company has NOT sold California consumers’ personal information. In addition, the Company will not sell California consumers’ personal information.

   Categories of Personal Information Collected In The Last 12 Months (as specified by California Statue)	Categories of Third Parties With Which Company Shared That Personal Information	Whether Company Disclosed That Personal Information For A Business Purpose Or A Commercial Purpose
   All of the below	For all categories: Company discloses personal information to government agencies, law enforcement, and other parties as required by law.	Yes.
   Category A: Identifiers	Our subsidiaries and affiliates Service Providers Our business partners		Yes
   Category B: Personal information listed in § 1798.80 of the California Customer Records statute	Our subsidiaries and affiliates Service Providers Our business partners		Yes
   Category D: Commercial information	Our subsidiaries and affiliates Service Providers Our business partners		Yes
   Category F: Internet or other electronic network activity information	Our subsidiaries and affiliates Service Providers		Yes
   Category G: Geolocation data	Our subsidiaries and affiliates Service Providers		Yes
   Category I: Professional, or employment-related information including:	Our subsidiaries and affiliates Service Providers Our business partners		Yes

3. Your California Privacy Rights

   As a California consumer, you have the following rights:

   • Right to Know: California consumers have the right to submit a verifiable request to know what personal information Company collects, uses, discloses, and sells.
   • Right To Delete: California consumers have the right to submit a verifiable request for deletion of their personal information that Company has collected or maintains.
   • Right to Opt Out of Sale: California consumers have the right to opt out of the sale of their personal information. California consumers under the age of 16 must opt in to the sale of their personal information, or their parent or guardian must opt in on their behalf. As noted above, Company did not sell California consumers’ personal information during the past 12 months.
4. How to exercise Your California Privacy Rights

   Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California consumers can exercise their rights to know and to delete in the following ways (including their right to opt out of sale if applicable):

   • By emailing Privacy@pubnub.com or
   • Contacting us by mail below.

   • How We Will Verify Your Request:

     The processes that we follow to verify your identity when you make a request to know or a request to delete are described below.

     • Requests Through Your Password-Protected Account:

       If you created a password-protected account with us before the date of your request, we will rely on the fact that your request has been submitted through your account as verification of your identity. We will require that you re-authenticate yourself before we disclose your personal information in response to a request to know and before we delete your personal information in response to a request to delete.

       You are responsible for protecting the security of your log-in credentials for your account. If we suspect fraudulent or malicious activity on or from your account, we will not respond to a request to know or a request to delete until we have been able to confirm, through further verification procedures, that you made the request.

     • Requests Other Than Through a Password-Protected Account:

       If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow depends on the nature of your request as described below:

       1. Requests To Know Categories Of Personal Information: We will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you that we already have in our records and that we have determined to be reliable for verifying your identity. (Relevant data points include your mobile phone number, your zip code, etc).

       2. Requests To Know Specific Pieces Of Personal Information: We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we will require you to sign a declaration under penalty of perjury that you are the California consumer whose personal information is the subject of the request.

       3. Requests To Delete Personal Information: Our process for verifying your identity will depend on the sensitivity (as determined by Company) of the personal information that you ask us to delete. For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above. For more sensitive personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.

       We have implemented the following additional procedures when verifying the identity of requestors:

       1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process.

       2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

   • Authorized Agents

     You may designate an authorized agent to exercise your right to know or your right to delete by submitting to us a completed “Authorized Agent Designation” form. You can obtain the designation form by contacting us at Privacy@pubnub.com

   • Company’s Non-Discrimination Policy

     Company will not unlawfully discriminate against California consumers who exercise their rights under the California Consumer Privacy Act.

   • Assistance for The Disabled

     Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact Privacy@pubnub.com for assistance.

   • Right To Information About Disclosures Of Personal Information For Direct Marketing Purposes:

     Under California law, California consumers can request information from us whether we have disclosed personal information to any third parties for the third parties' direct marketing purposes. California consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies may contact us using the contact information below.

5. For More Information

   For questions or concerns about Company’s privacy policies and practices, please contact us at Privacy@pubnub.com or write to us by mail at the business address listed in the About Us page