Sonder California Resident Privacy Notice
Last Updated: June 30, 2020
1. Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, Personal Information means 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, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”).
Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA.
The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold*, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of sources from which that information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
* Please note that the CCPA defines “sale” and “sell” very broadly and, in some cases, covers common industry practices, including providing you with a customized experience on our websites and apps or sending you marketing communications that we think may interest you.
Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Examples: Name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
C. Characteristics of Protected Classifications under California or Federal Law
Examples: Age (over 40), mental or physical disability, and sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions).
D. Commercial Information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information
Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
F. Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
G. Geolocation Data
Example: Precise physical location.
H. Sensory Information
Examples: Audio, visual, thermal, or similar information.
I. Professional or employment-related information
Examples: Job application or resume information, past and current job history, and job performance information.
J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
K. Inferences Drawn from Personal Information
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
2. Use of Personal Information
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
- Providing Services: Providing our services.
- Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
- Social Network Support: Updating your status on social networks, sending messages on your behalf to your social networks, and providing other features and services to you.
- Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks.
- Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
- Personalization: Personalizing your experience on our services such as presenting tailored content.
- Sending Messages: Sending you text messages or push notifications.
- Facilitating Payments: Facilitating transactions and payments.
- Deidentification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.
- Job Applications: Processing your job application.
- Safety Issues: Responding to trust and safety issues that may arise.
- Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use: Short-term, transient use.
- Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Research: Undertaking internal research for technological development and demonstration.
- Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
- Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
- Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.
3. Collection of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
- You/Your Devices: You or your devices directly.
- Users: Other users of our services.
- OS/Platform Provider: Operating systems and platforms.
- Social Networks.
- Resellers: Consumer data brokers.
- Partners: Business partners.
4. Disclosure of Personal Information
- Advertising Providers: Advertising technology companies, such as advertising networks.
- Analytics Providers.
- Government: Government entities.
- OS/Platform Provider: Operating systems and platforms.
- Social Networks.
- Landlords and Property Managers.
- Partners: Business partners.
- Vendors: Vendors and service providers.
- Integrated Third Parties: Third parties integrated into our services.
- Third Parties as Legally Required: Third parties as required by law and similar disclosures.
- Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
- Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
5. Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
- Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.
- Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
- Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with your full name, email address, phone number, and we will let you know if we need any additional information to verify your request.
- Right to Opt Out. The CCPA defines “sale” and “sell” very broadly and, in some cases, covers common industry practices, including providing you with a customized experience on our websites and apps or sending you marketing communications that we think may interest you. In some circumstances, you may opt out of the sale of your Personal Information. We do not currently sell any California resident’s Personal Information.
- Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
- Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.
- Submit Requests. To exercise your rights under the CCPA, please use the link above or call our toll-free number.
- Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.
6. Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
7. Contact Information
If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at [email protected] or write to us at: Sonder Holdings Inc., 500 E 84th Ave, Suite A-10 • Thornton, Colorado • 80229, United States.