Privacy Notice for California Residents

Last updated: August 18, 2022

ARAnet, Inc. dba Brandpoint (“Brandpoint,” “we,” or “us”) understands the importance of your privacy and we take our responsibility to protect your information seriously. This Privacy Notice for California Residents (“Notice”) supplements the information in the Privacy Policy posted on our website and applies solely to California residents.

This Notice explains our collection, processing, and disclosure of “personal information” relating to California consumers. Specifically, this Notice applies to our processing activity when we are acting as a “business” under the California Consumer Privacy Act of 2018, as may be amended from time to time (“CCPA”)—meaning that we control the purposes and means of processing your personal information.

Some of the personal information we collect may be exempt from some or all of the requirements under the CCPA. We may also receive your information in our capacity as a service provider to our customers; in which case, any questions you have relating to your personal information and your rights under California law should be directed to our customer that you have a relationship with.

Please read this Notice carefully before sharing information with us so you understand our practices regarding your information.

Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any 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. Personal information does not include information that is:

• Lawfully made available from government records;
• We have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or by the consumer;
• Made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience;
• Lawfully obtained, truthful information that is a matter of public concern;
• Deidentified or aggregate consumer information; or
• Information excluded from the CCPA’s scope, including personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act.

In the past 12 months, Brandpoint has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for business purposes.

Brandpoint has not “sold” or “shared” personal information about a consumer (as those terms are defined by the CCPA) in the past 12 months, including the categories of personal information below.

Brandpoint collects these categories of personal information from the following sources:

• Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, engaging in transactions with us, signing up to receive promotional or information communications from us, using our services, communicating with us about our services, or otherwise directly providing the information to us.
• Indirect and technology-based collection: We also collect certain information from you indirectly when you visit, use, or navigate our website. Brandpoint collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in our website privacy policy.
• Collection via social media: We may collect personal data about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
• Third-party collection: From time-to-time, we may obtain personal information regarding potential customers, or marketing or lead lists, from third party vendors. We use these, for example, to send you marketing communications.

Use of Personal Information

We collect and use your personal information for the following business or commercial purposes (as well as any other purposes as set forth in our Privacy Policy).

• Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner.
• Fulfilling transactions with your organization, processing payments, and managing the transaction, delivery, installation, and customer service processes.
• Communicating with you and responding to your inquiries about our services, including to provide you with promotional and informational communications regarding our services, informing you about new services, updating you about changes to our website, and investigating any concerns you have about our services or your transactions.
• Developing, updating, and improving our services, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding customers and potential customers.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the website or purchase and use of our services.
• Enforcing our agreements with customers and complying with our legal or regulatory obligations.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

Applicable Retention Periods

We will only retain your personal information in accordance with the standards set forth in our Privacy Policy .

Sensitive Personal Information

Brandpoint does not collect “sensitive personal information ” (as defined by the CCPA) about California consumers.

Sale or Share of Personal Information

As noted above, in the past twelve (12) months, Brandpoint has not sold or shared personal information of any category. Likewise, Brandpoint does not have actual knowledge of any sales of personal information regarding minors under 16 years of age.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Request Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past twelve (12) months. Specifically, you may request that we disclose:
   • The categories of personal information we collected about you;
   • The categories of sources for the personal information we collected about you;
   • The business and commercial purposes for collecting your personal information;
   • The categories of third parties to whom we disclose your personal information;
   • The specific pieces of personal information we collected about you; and
   • If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.
2. Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.
3. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.
4. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Exercising Your Rights

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: [email protected] with the subject line: “CCPA Request” or calling us at 952-278-0780. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer 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 of such consumer; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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 may also request that you provide additional information if needed to verify your identity or authority to make the request. 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 or the consumer on whose behalf you are making the request.

Response Timing and Format

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a 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 the request.

Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:

• Denying you goods or services.
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this page periodically for updates.

Data Sharing or Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Contact Information

If you have any questions or comments about this Notice, please contact us using the following information.

Phone: 952-278-0780
Email: [email protected]
Postal Address:
ARAnet, Inc. dba Brandpoint
Attn: Privacy Officer
850 Fifth Street South, Hopkins MN 55343