Effective May 25, 2023
Scope of Supplemental Privacy Notice
This additional California Notice (the “Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”) using certain services provided by subsidiaries of Costa Vida Management, LLC. For the purpose of this Notice, “Costa Vida”, “we” and “us” refer to the applicable subsidiary of Costa Vida Management, LLC.
This Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).
Unless otherwise expressly stated, all terms in this Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
Collection and Use of Personal Information
When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include de-identified or aggregated consumer information.
In the last 12 months, we have collected the following information about consumers for the following purposes. This does not mean that all of the data elements in the category of personal information were in fact collected but reflects our good-faith belief to the best of our knowledge that some of that information may have been collected about consumers for the listed purposes.
| Category of Personal Information | Categories of Sources | Commercial or Business Purpose |
| Identifiers, such as Account Name, Device ID, Email Address, IP Address, etc. | Consumers Consumers’ Devices Data Services Service Providers | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) Consumer acquisition |
| California Customer Records (Cal. Civ. Code § 1798.80(e)) such as Address, Name, Telephone Number. | Consumers Consumers’ Devices Data Services Service Providers Social Network Services | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (mail, phone, email, etc.) Consumer acquisition |
| Protected Classification Characteristics, such as age and gender. | Consumers Consumers’ Devices Data Services Service Providers Social Network Services | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) |
| Commercial Information, such as transaction amount, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Consumers Consumers’ Devices Data Services Service Providers Social Network Services | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) Consumer acquisition |
| Internet/Network Information, such as website or application or advertisement browsing history. | Consumers Consumers’ Devices Data Services Service Providers Analytic Services | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) |
| Location Information, such as establishment, Geolocation Data, IP Address, device shared location, and Wi-Fi connection location. | Consumers Consumers’ Devices Data Services Service Providers | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development/improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) Consumer acquisition |
| Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information. | Consumers Consumers’ Devices Data Services Service Providers Social Network Services Analytic Services | Detecting/protecting against security events Internal analytics and reporting Internal research Customer service Operate our services, business, and games Game mechanics or functionality Facilitate consumers’ social interactions Debugging existing intended functionality Product development / improvement Maintaining and enhancing service Auditing consumer interaction & transactions Advertising Direct marketing (phone, email, etc.) Consumer acquisition |
Disclosure of Personal Information
In the last 12 months, we have disclosed the following categories of personal information for a business purpose:
| Category of Personal Information | Disclosure for a Business Purpose | Sold* |
| Identifiers | YES | NO |
| California Customer Records (Cal. Civ. Code § 1798.80(e)) | YES | NO |
| Protected Classification Characteristics | YES | NO |
| Commercial Information | YES | NO |
| Internet/Network Information | YES | NO |
| Location Data | YES | NO |
| Inferences | YES | NO |
Costa Vida does not “sell” customer lists or personal information about our customers as most people would typically understand the term. However, with regard to certain information we collect about our customers through our services, games, and our website, we do contract for and allow certain third-parties to use such information for purposes of serving ads, marketing, and promotional offers to customers, for ad campaign measurement and analytics, and for ad fraud detection and reporting.
Please see our Advertising section below for more information.
To Whom We Disclose Personal Information
As described in the “Disclosure of Information Collected” section of the Privacy Notice, we share personal information within Costa Vida, and between Costa Vida subsidiaries, and with a variety of recipients for business purposes.
In addition to the categories of recipients identified in the “Disclosure of Information Collected” section of the Privacy Notice, we disclose personal information to, or allow access to personal information by, the following categories of recipients:
- Cloud Storage Providers
- Payment and Auditing Processors
- Security Safety Vendors and Service Providers
- Social Media Services
- Advertising and Marketing Partners
Advertising
We allow certain third-party partners to access or collect the seven (7) categories of personal information identified above for advertising purposes. These ad networks, social media companies and other third-party businesses may collect personal information directly from a browser or device through cookies or similar tracking technologies when a consumer visits or interacts with our websites, uses our apps or otherwise engages with us online. These third parties use your personal information to:
- serve relevant ads on our site, on other websites or mobile apps, or on other devices a consumer may use;
- to mail you relevant ads;
- to personalize content; and
- to perform other advertising-related services such as reporting, attribution, analytics and market research.
These third parties may use this personal information for their own commercial purposes in accordance with their own privacy policies, which may include providing this information to additional third parties, including other advertising networks.
Please see our Collection of Information notice for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
| The Right to Know | You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information we have collected about you; The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you, and the categories of third parties to whom this information was sold; and The business or commercial purposes for collecting or selling personal information about you. |
| The Right to Request Deletion | You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions. |
| The Right to Opt-Out of Personal Information Sales | You as a resident of California or Nevada have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. |
| The Right to Non- Discrimination | You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. |
| “Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). |
How to Exercise Your California Privacy Rights
To Exercise Your Right to Know or Right to Deletion
We will need to verify your identity before processing your request. In order to verify your identity, we may require matching identifying information you provide us to the information we maintain about you in our systems or a successful login to your account (as applicable). Although we try to limit the personal information collected in connection with a request to exercise the right to know(access request) and the right to deletion to that personal information identified in your California Personal Data Request, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
We use good-faith efforts to respond to a verifiable consumer request to know or to delete within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.
To Exercise Your Right to Opt-Out of Personal Information “Sales”
Unless you have exercised your right to opt-out of personal information “sales”, we may “sell” personal information to third parties, as that term is defined under California law. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include re”sell”ing this information to additional third parties.
Do Not Sell My Info
You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems and authenticate you as authorized to receive the information.
Once you make an opt out request, you may change your mind and opt back in to personal information sales at any time by contacting us at [email protected].
Submit Requests
- Access Request: Contact us via a California Personal Data Request; or call us at 1 (801) 797-2374
- Deletion Request: Contact us via a California Personal Data Deletion Request; or call us at 1 (801) 797-2374
- Exercise your right to opt-out: by clicking the following link: California Opt-Out Request
- Do Not Sell My Info Request
- The number of requests to know that the business received, complied with in whole or in part, and denied; 0
- The number of requests to delete that the business received, complied with in whole or in part, and denied; 0
- The number of requests to opt-out that the business received, complied with in whole or in part, and denied; 9
- The median or mean number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out. 1
If you have any questions or concerns regarding our Privacy Notice and privacy practices, please contact us via email at [email protected]; via telephone at 1 (801) 797-2374; or by writing us at the address provided in the “How To Contact Us” section of our Privacy Notice.
“Shine the Light”
If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your written request to the address provided in the Contact Information section of our Privacy Notice above and specify that you want a copy of your “Shine the Light” California Privacy Rights Notice. As provided under California Civil Code Section 1798.83, also known as the “Shine the Light” law, we provide our customers with the ability to “opt out” of having their personal information shared with independent affiliates and non-affiliated third parties for their direct marketing purposes. You may opt-out of having your personal information shared with these affiliated and non-affiliated third parties for their direct marketing purposes by utilizing the Exercise your right to opt Link above.
Minors Under Age 16
We do not collect the personal information of consumers we know to be less than 16 years of age.
Authorized Agent
Under (CCPA), a California resident may use an authorized agent to make a CCPA privacy request on the resident’s behalf. To make a request on behalf of a Costa Vida customer, the authorized agent must provide a copy of either (a) a letter signed by the customer authorizing the agent to submit a CCPA request on his or her behalf, or (b) a power of attorney, duly authorized and issued pursuant to California Probate law. The authorized agent must email one or both documents to [email protected] and include a phone number where the agent may be reached during regular business hours.
Household Requests
Under the CCPA, members of a California household can jointly request access to personal information for the household or the deletion of all household personal information. To make a household request, each member must first submit an Access or Deletion request on an individual basis by utilizing the California Personal Data Request LINK above or via email at [email protected]. After submitting the individual requests, each member must submit an email to [email protected] and request that their Access or Deletion requests be combined with the other members of their household. Each email must include the names of every person in the household joining in the request. If we do not receive email requests from every household member within 7 days of the date on which the first request was submitted, if we cannot verify any household member’s identity, or if we cannot verify that each member making the request is currently a member of the household, the request will not be processed, and Costa Vida will instead process each verified request on an individual basis.
Financial Incentives
We do not currently offer incentives in exchange for the retention or sale of personal information.
Updates
We may update this Notice from time to time and in the event, we make material changes to this Notice, we will provide notification via posting on our online services or mobile application, or through other relevant communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions, comments, or concerns regarding our Privacy Notice and privacy practices, please send an email to [email protected] (link sends email). For all other matters, please contact Costa Vida at 1 (801) 797-2374 or write us at the address provided in the “How To Contact Us” section of our Privacy Notice.