California Consumer Privacy Act (“CCPA”) Privacy Notice
How Your Information is Stored and Protected; Retention Periods.
Your information is stored in secured, password protected formats. Access to your information is limited to persons with a need to know, most often the persons processing transactions we have entered into with you. We have written document retention policies that govern the length of time we maintain records, your personal information will not be maintained any longer than is required under these policies unless your account with us remains open and active.
Information We Collect
We collect personal data which identifies, relates to, describes, defines, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (collectively “personal data”). In particular, we have collected (overall) data from the following categories of Personal Information from consumers within the past twelve (12) months (but not all data is collected as relates to each individual customer or transaction, more likely we collect only a few of these items for each transaction):
|Category of Personal Data
||Real name, alias, postal address, unique personal identifier, internet protocol address, account name, Social Security number, driver’s license number, or other similar identifiers.
|Personal Information Categories listed in the California Consumer Records statute (Cal. Civ. Code Section 1798.80 e)
||Name, signature, social security number, physical characteristics or description, address, phone number(s), passport number, driver’s license number or state I.D card number, insurance policy number, education, employment history, bank account number(s), credit card number, debit card number, or any other financial information, medical information or health insurance information. Some personal information included in this category may overlap with other categories.
|Protected Classification Characteristics under California and/or Federal Law
||Age (40 years old +), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition(s), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth related medical conditions, sexual orientation, veteran or military status, genetic information (including familial genetic information)
||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
||Genetic, physiological, behavioral, and biologic characteristics, or activity patterns used to extract a template or other identifier of identifying information, such as fingerprints, face prints, and voiceprints, iris or retinal scans, keystroke, gait, or other physical patterns, and sleep, health or exercise data.
|Internet or other Similar network activity
||Browsing History, search history, information on a consumer’s interaction with a website, application or advertisement.
||Physical location or movements
||Audio, Electronic, Visual, Thermal, olfactory, or similar information
|Professional or employment related information
||Current or past Job history or performance evaluations
|Non Public educational Information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g)
||Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student i.d. codes, student financial information, or student disciplinary records.
|Inferences drawn from other personal Information
||Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information does NOT include:
- Publically available information from official records.
- De-identified or aggregated consumer information.
- Information not within the scope of the CCPA.
We obtain the categories of Personal Information listed above from the following categories of sources and for the following purposes:
- Directly from our customers or their agents. For example from documents our clients provide us related to the products or services.
- Indirectly from our clients or their agents. For example, through information we collect from our client’s in the course of providing services to them, or preparing to provide products or services to them.
- Directly or indirectly from activity on our website (www.anritsu.com). For example, from submissions through our web portal or website usage details collected automatically.
- From third parties that interact with us in connection with the product we provide or the services we perform. For example from credit reporting agencies when we prepare to grant credit to a customer.
- To fulfill or meet the reason for which the information is provided. For example, if you provide us personal information in order to pay for a product or service delivered to you.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products and services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising for many contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary and appropriate to protect the rights, property or safety of us, our customers, and others.
- To respond to law enforcement requests and as required by applicable law, court orders or governmental regulations.
- As described to you when collecting your personal data or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy or liquidation, or similar proceeding, in which personal data held by us is part of the transaction.
We will not collect additional categories of personal data or use personal information we collect for materially different, unrelated or incompatible purposes without providing you notice. It is our practice that we do not, without your consent, “sell” as defined in the CCPA personal information for monetary or other considerations.
Sharing Personal Information
We may disclose your personal information to subsidiaries or affiliates or to a third party we have contracted with for a business purpose. When we disclose personal information for a business purpose, we contract with that third party with contractual clauses that describe the purpose of the contract and that requires the recipient to both keep that personal information confidential and not disclose or use it for any purpose except for performing under out contract.
In the past twelve (12) months, we have disclosed the following categories of personal information for business purposes only:
- California Customer Records personal information categories.
- Commercial information
- Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our subsidiaries or affiliates.
- Third party service providers with whom we have contractual relationships.
- Third parties to whom you or your agents have authorized us to disclose your personal information to in connection with the products or services we provide to you.
Per our policy, we have not, within the past twelve (12) months, sold any personal information.
Your Rights and Choices
The CCPA provides California consumers with specific rights regarding their personal information. This provision explains how to avail yourself of these rights.
Access to Specific Information and Data Portability Rights
You have the ability to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive a verifiable request from you, we will disclose to you:
- The types of personal information we collected about you.
- The types of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties which whom we shared that personal information.
- If we sold or disclosed your personal information for a business purposes, two separate lists disclosing: a) sales, identifying the personal information types that each category of recipient received, and b) disclosures for a business purpose, identifying the personal information types that each recipient received.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from 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.
Please note that we may reject your request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of other consumers to exercise their right to free speech, or exercise another right provided for by law.
- Comply with provisions of state of federal law.
- Engage in public or peer review scientific, historical, or statistical research in the public interest that adheres to other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with the consumer expectations based upon your relationship with us.
- Comply with any legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability or deletion rights described above, please submit a verifiable consumer request to us by either:
- 1-800 Anritsu
- Visiting www.anritsu.com and clicking on the provided link: https://www.anritsu.com/subscription/privacy-contactus.aspx
Only you or your authorized agent may make a verifiable consumer request. You may also make a verifiable request on behalf of any minor child.
You may only make a verifiable request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information, or an authorized representative.
- Describe your request with sufficient detail that allows us or properly understand it, and respond to it.
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 strive to respond to a verifiable consumer request within forty five (45) days of its receipt. If we require more time (up to ninety (90) days) we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to your via that account. If you do not have an account with us, we will deliver our written response to you by mail or electronically, at your option. Any disclosure we provide will only cover the twelve (12) month period preceding the verifiable consumer’s request. The response we provide will also explain the reasons we cannot comply with any request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should 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.
We will not discriminate against you for exercising your CCPA rights. Unless permitted under CCPA, we will not:
- Deny you goods or services.
- Charge you a different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level of quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services of a different level or quality of services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice posted on our website homepage.
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal information, your choices or rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
490 Jarvis Drive
Morgan Hill, CA95037
Attn: General Counsel