CCPA

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Privacy Notice for California Residents who visit or use Paul Hafalla sites, products and services.

Preamble

Although Paul Hafalla is legally exempted from the California Consumer Privacy Act, we still feel it’s important to our California clients, visitors, and employees to respect its terms. Privacy is a human right. We take it seriously. We do not sell or buy Personal Information. Most of this document is “legalese”, although we have tried hard to ensure it’s as easy to read as possible. If you have any questions, please contact us at info.paulhafalla@gmail.com.

Privacy notice for California residents

Effective Date: December 25th, 2019

This Privacy Notice for California Residents extends and supplements Paul Hafalla’s privacy policy (http://www.paulhafalla.com/legal/privacy-policy.html) and applies solely to visitors who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

On PaulHafalla.com (our “Website”), we collect information that may identify, relate to, describe, reference, could be capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, our Website have collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category

Collected

A. Identifiers. YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). YES

C. Protected classification characteristics under California or federal law. NO

D. Commercial information. YES

E. Biometric information. NO

F. Internet or other similar network activity. YES

G. Geolocation data. YES

H. Sensory data. NO

I. Professional or employment-related information. NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). NO

K. Inferences drawn from other Personal Information. NO

Personal Information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Paul Hafalla obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our website.

• Indirectly from you. For example, from observing your actions on our Website.

• From third-party business partners such as marketing automation tools, social media sites, and analytics providers.

Use of Personal Information

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

• To provide, support, personalize, and develop our Website, products, and services.

• To create, maintain, customize, 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 personalize your Website experience and to deliver content and product and service offerings relevant to your interests.

• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

• Paul Hafalla will not collect additional categories of Personal Information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Paul Hafalla may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

• Service providers, such as payment processors and accounting services

• Data aggregators, such as Google Analytics

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Paul Hafalla has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.

Category B: California Customer Records Personal Information categories.

Category D: Commercial information.

Category G: Geolocation data.

We disclose your Personal Information for a business purpose to the following categories of third parties:

Service providers

Sales of Personal Information

In the preceding twelve (12) months, Paul Hafalla has not sold Personal Information.

Your Rights and Choices

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.

Access to Specific Information and Data Portability Rights

You have the right to request that Paul Hafalla disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we have collected about you.

• The categories of sources for the Personal Information we have collected about you.

• Our business or commercial purpose for collecting or selling that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you (also called a data portability request).

If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

• sales, identifying the Personal Information categories that each category of recipient purchased; and

• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Paul Hafalla delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception 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 we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

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 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.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by any of the following:

Calling us at +63 999 835 5013, or

Emailing us at info.paulhafalla@gmail.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

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.

For instructions on exercising sale opt-out rights, see Exercising Access, Data Portability, and Deletion Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.

Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info.paulhafalla@gmail.com.

Changes to Our Privacy Notice

Paul Hafalla reserves the right to make changes to this Privacy Notice at our discretion and at any time. When we make material changes to this Privacy Notice, we will post the updated Privacy Notice on the Website and update the Privacy Notice’s effective date. If you have an account with us,we will notify you of any material changes via email. Your continued use of our Website following the notification and/or posting of the updated Privacy Notice constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which Imarc collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: +63 999 835 5013

Email: info.paulhafalla@gmail.com