CA Privacy Notice

a. California Consumer Privacy Act of 2018

The following applies to California residents, supplements this Policy, and is provided as part of our efforts to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Information concerning the CCPA may be found here.

Please note that the CCPA does not currently apply in all respects to personal information that We collect from a person in the course of the person acting as a job applicant, employee, owner, director, officer, or contractor of Asteya to the extent that the person’s personal information is collected and used by Us solely within the context of the person’s role, or former role, as a job applicant, employee, owner, director, officer, or a contractor of Asteya. The CCPA also does not apply to personal information that We collect that constitutes emergency contact information of a person acting in any of the aforementioned roles to the extent that the personal information is collected and used solely within the context of having an emergency contact on file. Lastly, the CCPA does not apply to personal information that is necessary for Us to retain in order to administer benefits relating to a person’s capacity in any of the aforementioned roles to the extent that the personal information is collected and used by Asteya solely within the context of administering those benefits.

Collection of Personal Information

The CCPA defines “Personal Information” as: “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The disclosures and explanations of your rights in this Section 8 apply only to the Personal Information that We collect about you now or that We may collect about you in the future.

Please note that the categories of Information including any Personal Information that We collect may vary by individual.

Sources of the Personal Information We Collect

We may collect Personal Information from the following sources:

Purposes for Which We Collect Personal Information

We use Personal Information to support our business functions including with respect to the following, where applicable:

The Categories of Third Parties with Whom, and Purposes for Which, We Share Personal Information

We may obtain Personal Information about you from third parties and may combine this information with other Personal Information We maintain about you. If We do so, this Policy governs any combined information that We maintain in personally-identifiable format.

As noted above, Asteya shares information with its affiliates and Joint Venture Partners consistent with the provisions of the California Consumer Privacy Act. At this time, Asteya shares certain information with [FSL…but if others add here]. FSL’s own California Notice of Collection can be found here.

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

We may share Personal Information with third parties for the following purposes:

Access to Personal Information

You have the right to request, in accordance with applicable law, that We disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Please note that the CCPA limits our ability to provide you with the requested information only after We receive a verifiable consumer request from you or a person registered with the Secretary of State that is authorized by you to act on your behalf. Once We receive a verifiable consumer request, We will disclose to you:

Please note that the CCPA does not require Us to retain any Personal Information collected for a single, one-time transaction, if that Personal Information is not sold or retained by Us. It also does not require Us to reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information.

Deletion Requests

You may request, in accordance with applicable law, that Asteya delete the Personal Information that We collected about you and retained, subject to certain exceptions. Once We receive a verifiable consumer request, We will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies in support of our business need to retain some or all of your Personal Information.

We may deny your deletion request if retaining the Personal Information is necessary for Us or our service provider(s) to:

Access, Data Portability, and Deletion Requests

To access, seek data portability, or request that We delete your Personal Information, please submit a verifiable consumer request to Us by either:

Only you, or someone legally authorized 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 twelve (12) month period. The verifiable consumer request must:

After We receive a verifiable consumer request from you, We will take steps to determine whether the request being made is a verifiable consumer request. Given the nature of the Personal Information requested, We will require authentication of your identity. 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.

Response Timing and Format

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

Any disclosures We provide will only cover the twelve (12) month period preceding our receipt of your verifiable consumer request. The response We provide will also explain the reason(s) 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 to 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.

Personal Information Sales Opt-Out and Opt-In

Asteya does not sell Personal Information.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. We will not:

b. California Shine The Light Law

Asteya does not share your Information with non-affiliated third parties for their own marketing use without your consent. Asteya does share your Information with corporate affiliates.

Effective Date: July 22, 2021

Last modified: July 22, 2021