Supplemental California Privacy Disclosures

Fireflow Creative Collective LLC addresses these California Privacy Disclosures specifically to California residents where we determine the means and purposes of processing their personal information. Any terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and its implementing regulations (“CCPA”), carry the same meaning when used in these Disclosures. These Disclosures do not cover our collection, use, or disclosure of California residents’ personal information where an exception under the CCPA applies.

1. Personal Information Processing Activities over the Past 12 Months

Below, we outline the categories of “personal information” and “sensitive personal information” that we may have collected from California residents in the last 12 months in relation to their use of our services. Note that not all categories of personal information will be relevant to every individual.

Categories of “personal information” as defined by the CCPA that Fireflow Creative Collective LLC may collect:

Information that identifies, relates to, describes, or is capable of being associated with a particular individual, such as name, signature, social security number, address, telephone number, payment details, excluding publicly available information from government records.
Characteristics of protected classifications under California or federal law.
Commercial information, including details about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Geolocation data.
Inferences drawn from any of the information listed above to create a profile about a consumer reflecting preferences and characteristics.

Categories of “sensitive personal information” as defined by the CCPA that Fireflow Creative Collective LLC may collect:

We do not intentionally collect or store sensitive personal information. Any sensitive data inadvertently collected is handled in accordance with our data retention policies and the CCPA.

2. Sources of Personal Information

We collect personal information from California residents through the following sources:

Directly from California residents or their representatives.
From devices associated with California residents.
From third-party service providers, including social media platforms, data aggregators, and automatically via cookies and similar technologies.
From public records (e.g., federal, state, or local government sources).

We do not have actual knowledge that we sell or share, for cross-context behavioral advertising, the personal information of California residents under 16 years of age.

3. Using and Disclosing Personal Information

We use personal information for the purposes outlined in Section 2 of our Privacy Policy. For employment-related matters, different personal information may be collected and used, which is governed by our candidate and employee privacy notices. We only use and disclose California residents’ sensitive personal information as authorized under Section 7027(m) of the CCPA Regulations.

We disclose personal information to our service providers and other categories of recipients as described in Section 4 of our Privacy Policy. Because we rely on service providers for IT hosting and backup, we share all categories of personal information we collect with these providers, under appropriate contractual provisions.

We may use de-identified information for any purpose. We commit to maintaining and using de-identified information in its de-identified form and not to attempt to re-identify the information, except to verify that our de-identification processes meet applicable legal standards.

4. CCPA Rights

As a California resident, you have the following rights under the CCPA:

Right to Know: You have the right to request information about the personal information we have collected about you, including the categories of personal information, the sources of collection, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties with whom we share personal information, and the specific pieces of personal information we have collected. This right may be exercised up to twice in a 12-month period.
Right to Delete: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
Right to Correct: You have the right to request the correction of inaccurate personal information that we maintain about you.
Right to Opt Out: You have the right to opt out of the sale or sharing of your personal information by us.
Right to Limit Use of Sensitive Personal Information: You have the right to limit our use and disclosure of your sensitive personal information to the purposes specified in Section 7027(m) of the CCPA Regulations. We do not use or disclose sensitive personal information for any purposes other than those specified in Section 7027(m).
Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA, in violation of California Civil Code § 1798.125.

5. How to Exercise CCPA Rights

Methods of Submission and Instructions: To exercise your rights to know, delete, or correct your personal information, please contact us using the contact information provided below and describe your request.

Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by following the steps outlined under “Authorized Agents” below. To verify your identity or that of your authorized agent, we may request additional information. If you do not provide sufficient information for verification, we will not be able to fulfill your request. Any personal information provided in connection with a request will be used solely to verify your identity and to fulfill your request.

Authorized Agents: You may designate an authorized agent to make a CCPA request on your behalf if:

The authorized agent is a natural person or business entity and provides proof that you granted them signed permission to submit the request; and
You directly confirm with us that you have provided the authorized agent with permission to submit the request on your behalf.

If your authorized agent holds a power of attorney under Probate Code sections 4121 to 4130, it may not be necessary to perform these steps, and we will respond to any request from such an authorized agent in accordance with the CCPA.

6. Contact Information

If you have any questions regarding this Privacy Policy or wish to exercise your privacy rights, please contact us by submitting a help request or by emailing us at [email protected].