Notice Regarding the Collection of Personal Information
Categories of Personal Information We Collect and Their Sources
The following are the categories of personal information we collect from consumers and the source of collection, in accordance with the categories of personal information enumerated in the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (we will refer to both as CCPA in this document). These are also the categories of information we collected in the past 12 months. We retain the categories of personal information detailed below for a period of 90 days after the last date that we collected any of the consumer’s data. We delete the information after 90 days. We do not use or disclose sensitive personal information.
Business Purposes of the Personal Information We Collect and Sell or Share
Sharing and Selling Your Personal Information
The chart below explains about the personal information we shared for online behavioral-targeted ads and sold to other parties in the preceding 12 months. Other than this sale and sharing, we have not disclosed your personal information for a business purpose in the preceding 12 months. We do not have actual knowledge that we share the personal information of consumers under 16 years of age.
Your Data Privacy Rights
Right to Know
You have the right to know the following, which we will provide to you after we receive a verifiable request from you:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting personal information;
- The categories of third parties with whom we share personal information, if any; and
- The specific pieces of personal information we have collected about you
Right to Correction and Deletion
As permitted by regulation, 33Across will treat correction requests as a request to delete.
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your personal information from our records;
- Direct any service providers with whom we have shared your personal data, to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary 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 within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or
- Comply with an existing legal obligation.
We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CCPA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Right to Designate an Authorized Agent to Submit CCPA Requests on Your Behalf
You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
Submitting CCPA Requests
If you would like to exercise any of your CCPA rights described above, please:
- Complete a consumer request form available on our website at 33across.com/user-data-portal/ or
- Call us, toll-free, at 1-888-297-4094 or
- Utilize the California Data Broker Delete Request and Opt-Out Platform (DROP). We are a registered data broker under the California Delete Act. We actively monitor and process verifiable deletion and opt-out requests submitted by consumers or their authorized agents directly through the California DROP system.
We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information to you, by using a two-points-of-data verification process. Please note that requests received securely via the California DROP mechanism are verified by that platform and do not require this additional manual identity verification step. This ensures a streamlined deletion process.
Right to Opt-Out of the Sale or Sharing of Personal Information
We share and sell your personal information in certain instances, as explained above under “Sharing and selling your personal information”. You have a right to opt-out of that sharing and sale. If you would like to exercise your right to opt-out, please use the form available on our website at 33across.com/user-data-portal. Additionally, we respect global privacy controls and opt-out requests initiated through the California DROP mechanism, ensuring your preferences are applied comprehensively across our systems without requiring further verification.
Annual Consumer Request Metrics
The California Consumer Privacy Act (“CCPA”) and the California Delete Act require certain businesses to compile and disclose information regarding their compliance with the CCPA for the previous calendar year. Statistics for the reporting period of January 1, 2024 – December 31, 2024 are as follows:
*Any denials were based on consumers abandoning their request by not verifying their identity as required by CCPA.
Median Completion Time: 10 days
Mean Completion Time: 29 days
