Privacy Policy for California Residents

This Privacy Policy for California Residents (this “Policy”) supplements the information contained in our general Privacy Policy (here) and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). PURE (“Company,” “we,” “our,” or “us”), operated by Online Classifieds AG, Baarerstrasse 8, 6300 Zug, Switzerland, CHE-274.401.166, adopts this Policy, and the Company’s Notice at Collection (here) to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Policy.

1. Information we collect

a. Personal Information

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, household, or device constitutes personal information ("Personal Information"). Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information. In the last twelve (12) months, we have collected the following categories of Personal Information:

Category	Examples	Collected
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s licence number, passport number, or other similar identifiers.	Yes
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 licence 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.	Yes
Protected classification characteristics under California or federal law	Age (40 years or older), race, colour, 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
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information	Genetic, physiological, behavioural, 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.	Yes
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data	Physical location or movements.	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
Professional or employment-related information	Current or past job history or performance evaluations.	Yes
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
Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.	No

b. Sensitive Personal Information

Personal Information that reveals any of the information listed in the table categories below constitutes sensitive personal information (“Sensitive Personal Information”). While we collect information that falls within the Sensitive Personal Information categories listed in the table below, the CCPA does not treat this information as sensitive because we do not collect or use it to infer characteristics about a person. In the past 12 months, we have collected the following categories of Sensitive Personal Information:

Sensitive Personal Information Category	Collected
Government identifiers, such as your Social Security number, driver’s licence, state identification card, or passport number	Yes
Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password	No
Precise geolocation	Yes
Racial or ethnic origin	No
Citizenship or immigration information	Yes
Religious or philosophical beliefs	No
Union membership	No
Contents of a consumer’s mail, email, and text messages, unless the Company is the intended recipient of the communication	No
Genetic data	No
Unique biometric information used for identification	Yes
Health information	No
Sex life, or sexual orientation information.	Yes

2. Sources of information

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you when you provide it to us.
Indirectly from you. For example, from observing your actions on our Website.
From third parties, for example, our business and marketing partners.

3. Use of personal information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

To fulfil or meet the reason you provided the Personal Information and Sensitive Personal Information.
To provide, support, personalise, and develop our website, products, and services.
To create, maintain, customise, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
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 personalise your Website experience and to deliver content and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email.
Communicate with you about products, services, offers, promotions, contests, sweepstakes, rewards, and events, and provide other news and information about the Company and our select partners.
Link or combine with other information we receive from third parties to help understand your needs and provide you with better service.
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity.
To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
To maintain, improve, upgrade, or enhance our products and services.
For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including billing and collections.
To maintain employment records for any California employees and contractors.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To comply with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions).
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganisation, 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 about our website users and/or consumers is among the assets transferred.
Recruit and process employment applications, including verifying eligibility for employment and conducting background and related checks.

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 with notice.

4. Information sharing

We do not sell your Personal Information. We may share the categories of Personal Information we collect with third parties for cross-context behavioural advertising, as indicated in the chart below. To opt-out of Personal Information sharing, please visit “Do Not Sell or Share My Personal Information."

We may disclose your Personal Information to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information
Personal Information Category	Category of Third-Party Recipients of the Business Purpose Disclosures	Sharing
Identifiers	Data Analytic Providers Internet Cookie Data Recipients Operating Systems and Platforms Other service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein	Advertising networks
California Customer Records Personal Information categories	Service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein	None
Protected classification characteristics under California or federal law	Data Analytic Providers Other users as part of the general operation of the service	None
Commercial information	Data Analytic Providers Other service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein.	None
Biometric information	None	None
Internet or other similar network activity	Data Analytic Providers Internet Cookie Data Recipients Operating Systems and Platforms Other service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein	Advertising networks
Geolocation data	Data Analytic Providers Other users as part of the general operation of the service Other service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein	Advertising networks
Sensory data	None	None
Professional or employment-related information	Service providers and professional services organisations who assist us in relation to the business or commercial purposes laid out herein	None
Non-public education information	None	None
Inferences drawn from other Personal Information	None	None
Sensitive Personal Information
Sensitive Personal Information Category	Category of Third-Party Recipients of the Business Purpose Disclosures	Sharing
Government identifiers	None	None
Complete account access credentials	None	None
Precise geolocation	None	None
Racial or ethnic origin	None	None
Citizenship or immigration information	None	None
Religious or philosophical beliefs	None	None
Union membership	None	None
Contents of a consumer’s mail, email, and text messages	None	None
Genetic data	None	None
Unique biometric information used for identification	None	None
Health information	None	None
Sex life, or sexual orientation information	Data Analytic Providers Other users as part of the general operation of the service	None

We do not use or disclose Sensitive Personal Information for purposes other than the Permitted Sensitive Personal Information Purposes, as that term is defined in the CCPA.

Shine the Light Disclosure: The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We currently do not disclose your personal information to third parties for their own direct marketing purposes.

5. Your rights under the CCPA

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.

Right to Know: 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 your request and confirm your identity (see Exercising Your Rights), 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 Personal Information categories shared, if any, and the categories of third parties with whom we shared that Personal Information.
The Personal Information categories disclosed for a business purpose, if any, and the categories of parties receiving that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).

Right to Delete: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information 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 the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract you have entered into with us.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Help ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes.
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.

Right to Correct: You have the right to request that we correct any inaccuracies in your Personal Information we hold about you, considering both the Personal Information’s nature and processing purposes. Upon receiving your request (see Exercising Your Rights), we will use commercially reasonable efforts to correct the Personal Information on our existing systems or alternatively, delete the contested Personal Information if the deletion does not negatively impact you or if you consent to such deletion.

Right to Opt-Out: You have the right to prevent the sharing of your Personal Information to third parties at any time by requesting that we stop doing so (see Exercising Your Rights).

Right to Limit Sensitive Personal Information: You have the right to limit how we use and disclose your Sensitive Personal Information by requesting that we restrict our use and disclosure of such Sensitive Personal Information to the “Permitted Sensitive Personal Information Purposes”, which allow us to collect, use, and disclose Sensitive Personal Information for the following purposes, even after you exercise your limitation rights:

To perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.
To prevent, detect, and investigate security incidents compromising Personal Information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at our business and to prosecute those responsible for those actions.
To ensure individuals' physical safety.
For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with that us, so long as we do not: (i) disclose your Sensitive Personal Information to another third party; or (ii) use it to build a profile about you or otherwise alter your experience outside your current interaction with us.
To perform services for the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing, storage, or providing similar services for the business.
For products, services, or devices that we own, manufacture (directly or indirectly), or control, to: (i) verify or maintain the quality or safety of the product, service, or device; or (ii) improve, upgrade, or enhance the service or device.
For purposes that do not infer characteristics about you.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.

6. Exercising your rights

Rights to Know, Delete, or Correct: Please email us at [email protected] to exercise your rights to know, delete, or correct, as described above.

Right to Opt-Out: To exercise your right to opt-out, please submit a request by either:

Visiting “Do Not Sell or Share My Personal Information” and completing the submission form.
Emailing us at [email protected]

Right to Limit Use and Disclosure of Sensitive Personal Information: Because we neither use nor disclose your Sensitive Personal Information in ways that exceed the Permitted Sensitive Personal Information Purposes (see Your Rights Under the CCPA), there are no instances of Sensitive Personal Information usage that could be subject to limitation. However, if you have any questions about this right, please feel free to email us at [email protected].

Submission and Response

Once you have submitted a request, we will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Also, we may ask you to describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Only you or a person that you authorise to act on your behalf, may make a Verifiable Consumer Request, as defined in the CCPA, related to your Personal Information. You may also make a Verifiable Consumer Request on behalf of your minor child.

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. Additionally, we will not honour your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights. We will advise you in our response if we are not able to honour your request. We will not provide social security numbers, driver’s licence numbers or government issued identification numbers, financial account numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorised access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

Making a Verifiable Consumer Request does not require you to create an account with us. We will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor's identity or authority to make the request.

We commit to respond to a Verifiable Consumer Request within 45 days of its receipt. If we require more time (up to a total of ninety (90) days), we will inform you of the reason and extension period in writing.

Authorised Agent

You may authorise an agent to exercise your rights on your behalf. When a request is submitted by an authorised agent, the Company will require the requestor to: (i) provide the authorised agent’s written permission to do so; and (ii) will require the requestor to verify their own identity directly with the Company. If the Company is unable to verify the identity of the requestor or does not receive proof from the authorised agent that the requestor authorised the agent to act on the requestor’s behalf, the request will be denied.

7. Changes to our Privacy Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

8. Contact information

If you have any questions or comments about this Policy, the ways in which the Company collects and uses your information, or your choices and rights with respect to your Personal Information, please do not hesitate to contact us by email at [email protected].

Alternatively, you can write to:

Online Classifieds AG
Baarerstrasse 8
6300 Zug
Switzerland

Effective date: December 2024

The previous versions:

01 September 2024

Privacy Policy for California Residents