California Privacy Policy 

Last modified: 1 September 2021

The California Consumer Privacy Act (“CCPA”) requires Flourish Labs LLC  (“Flourish Labs”, “we”, “us” or “our”) to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. This California Privacy Policy (the “CA Policy”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”). This CA Policy describes 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 CA Policy have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA. 

When we use the term “personal information” in this CA Policy, 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. For the purposes of this CA Policy, personal information does not include:

  • Publicly available information from government records;
  • De-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer;
  • Information excluded from the CCPA’s scope, such as:
    • 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;
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
  • Information relating to our employees, contractors and other Flourish Labs personnel, including crisis personnel.

Collection, use and sharing of Personal Information

We collect personal information for the business and commercial purposes described in the “Our collection of Personal Information” and “Our use of Personal Information” sections of our Privacy Policy. We share this information with the categories of third parties described in the “Our sharing of Personal Information” section of our Privacy Policy.

We do not sell personal information.

In the last 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name and email address;
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your phone number;
  • Internet/Network Information, such as device information, logs and analytics data;
  • Characteristics protected by law; for example, you might provide your gender as part of a research survey for us;
  • Geolocation data, such as your location based on your IP address;
  • Sensory information, such as recordings of any phone calls between you and Flourish Labs
  • Other Personal Information, including information you submit into the feedback form and any communications between you and Flourish Labs; and
  • Inferences we make, such as likelihood of retention or attrition.

We collect this information from the following sources: directly from you, from third parties such as our service providers, from your browser or device when you use our Services (e.g., visit our Websites or use our App), or from third parties that you permit to share information with us (e.g., wearable device providers). Please see the “Our collection of Personal Information” section of our Privacy Policy for more information about the sources of personal information we collect.

Your California privacy rights

If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

  • Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
  • Request deletion of personal information we collect or maintain;
  • Opt out of any sale of personal information; and
  • Not receive discriminatory treatment for exercising your rights under the CCPA.

How to exercise your California consumer rights

To exercise your Right to Access, Right to Know or your Right to Deletion, please submit a request by emailing us at california-rights-request@flourishlabs.net with the subject line “California Rights Request”, or by filling out the “California Consumer Rights Request Form” below.

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, and/or date of last interaction with customer service.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Authorized agents

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Policy where we can verify the authorized agent’s authority to act on your behalf. 

For requests to know or delete personal information, we require the following for verification purposes: 1) a power of attorney valid under the laws of California from you or your authorized agent; or 2) sufficient evidence to show that you have: provided the authorized agent signed permission to act on your behalf; and verified your own identity directly with us pursuant to the instructions set forth in this CA Policy; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. 

For requests to opt-out of personal information “sales”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Children under 16

Please refer to the “Children’s Personal Information” section of our Privacy Policy.

Updates to this CA Policy

We will update this CA Policy from time to time. When we make changes to this CA Policy, we will change the date at the beginning of this CA Policy. If we make material changes to this CA Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact us

We welcome your feedback on this CA Privacy Policy. If you have any comments or questions, please contact us at: https://projecthap.com/contact/

California Consumer Rights Request Form

If you are an authorized agent submitting on behalf of a consumer:

In certain circumstances, we may require additional information if we are unable to verify your request based on the information you have provided. The personal information submitted in connection with this request will be used for the purpose of processing your request.

If you’re an Authorized Agent submitting a request on behalf of a consumer, we will contact you to request written authorization from the consumer indicating you’ve been authorized to submit a request on their behalf. The authorization must be signed by both parties. All authorizations not signed will be rejected.