Do Not Sell

Last Updated: June 1, 2019

Effective Date: June 1, 2019

Privacy Toll Free, LLC does not sell your personal information to third parties, so no opt-out or opt-in choices apply. When you sign up for CCPA Toll Free, you can embed this privacy preferences request manager in your privacy policy and/or Do Not Sell page:

If you would like to exercise any of your other California Consumer Privacy Act rights, please email us at privacy@ccpatollfree.com or call us toll free at 1-866-I-OPT-OUT and enter Service Code 1. Here is a summary of your CCPA rights:

You have the right to know, to the extent applicable:

  1. The categories of sources from which we collected personal information about you.
  2. The categories of personal information we collected about you.
  3. The categories of personal information that we disclosed about you for a business purpose.
  4. The categories of third parties with whom we share personal information.
  5. The categories of personal information we sold about you.
  6. The categories of third parties to whom we sold your personal information, by category, for each third party to whom we sold the information.
  7. Our business or commercial purposes for collecting or selling personal information.
  8. The specific pieces of personal information we collected about you.

You have the right to request, to the extent applicable:

  1. That we do not sell your personal information to third parties.
  2. That we delete your personal information.
  3. That we provide you with a copy of your personal information that we collected.

Before we can respond to your request, we’ll need to verify your identity.

See our Privacy Policy under the caption “California Consumer Privacy Act Disclosures” for more information about the CCPA.

Why is this page here and do I need a page like this on my website?

The California Consumer Privacy Act (CCPA) requires businesses subject to the law to provide consumers residing in California with the right to opt out of the sale of their personal information through a clear and conspicuous link on their main homepage called “Do Not Sell My Personal Information.”

If a business maintains a separate webpage dedicated to California consumers rights, it can put the Do Not Sell link on that page instead of on its main homepage as long as it takes reasonable steps to direct California consumers to that page.

The California Attorney General may also develop a, “recognizable and uniform opt-out logo or button” for all businesses to promote consumer awareness of the right to opt out. If the AG develops this, businesses should use it instead of a text link.

Personal information is information that identifies or relates to a particular consumer or household including name, postal address, email address, IP address, social security number, personal property records, purchasing histories, biometric information, internet activity such as browsing or search history, geolocation data, employment information, education information and inferences drawn from this information, in so far as it is not publicly available information.

Businesses may not require a consumer to create an account in order to opt out of sales of personal information, and they may only use the information collected during the opt-out to comply with the opt-out.

When a consumer opts out, businesses must not sell their personal information and cannot ask them to opt-in again for 12 months from the date of opt out.

Do I need to train my employees and vendors about the CCPA?

Yes. Businesses also need to train their staff who handle consumer requests about privacy, including making sure they:

  • Know about the CCPA generally
  • Can inform consumers about how to exercise their rights
  • Understand how to access the “Do Not Sell My Personal Information” page and how it works
  • Do not sell the personal information of consumers who opt out (or who have not opted in, in the case of children aged 16 or younger)
  • Wait 12 months before asking consumers who opted out to opt in again
  • Use any personal information collected as part of an opt out only to process the opt out
  • Respect opt outs made on behalf of another person (Note: the California attorney general AG is supposed to provide details about this)

Do I need to update my privacy policy for CCPA?

Yes. Businesses need to update their privacy policies to comply with the California Consumer Privacy Act. What follows is a point-by-point list of requirements in the law as well as sample disclosure applicable to our Privacy Toll Free, LLC business. The sample disclosure below is lengthy because it tracks the CCPA literally. For a plain-English version of CCPA disclosures, see our privacy policy under the heading “California Consumer Privacy Act Disclosures.”

  • A description of a consumer’s rights pursuant to Section 1798.120:
    • Your Right to Opt Out. If you’re a consumer residing in California and we sell your information to third parties, you can tell us at any time not to sell your personal information. This right to opt-out applies if we do not know your age or if we know you are older than age 16.
    • Your Right to Opt In. If we have actual knowledge that you are between ages 13 and 16 (e.g., based information we collect, or because someone informed us), we will never sell your personal information without your affirmative authorization. If we have actual knowledge that you are younger than 13, we will never sell your personal information without your parent or guardian’s affirmative authorization. This is your right to opt in.
    • Do We Sell Your Personal Information? At this time, we [do not] sell your personal information [and you can opt out at any time] [so no opt out choices apply]. If you opt out, or for children 16 and younger, if you have not opted in, we will not sell your personal information to third parties unless you expressly authorize us to do so.
  • A description of a consumer’s rights pursuant to Section 1798.110:
    • California consumers have the right to request that we disclose to you:
      • The categories of personal information it has collected about that consumer.
        • We collect customary “web log” data about the device you use to access our services, such as which browser you use, your device platform (e.g., iPhone vs. Windows PC), your screen resolution and your device language setting.
        • We collect registration data when you create an account on our site, such as your name, company name, email address and password.
        • We collect payment data when you purchase our services, such as your credit card number and billing address.  
        • We collect service usage data, such as which services features you and your consumers interacting with our services access, how often you and they access them and at what time you and they access them.
        • We collect the content you transmit to our services, including your compliance notes and the outgoing greetings your consumers hear when they call our toll-free number and enter one of your service codes.
        • We collect the content your consumers transmit to us when they interact with our services, including the voicemails they leave for you.
        • We collect marketing data such as your email address when you sign up for our mailing list.
      • The categories of sources from which the personal information is collected.
        • We collect personal information from you actively when you enter it into our services (e.g., your name).
        • We collect personal information passively when you access our services, to the extent your web brower provides this information to our servers (e.g., your operating system) and also based on your service usage (e.g., when and from what IP address you log on to our services).  
      • The business or commercial purpose for collecting or selling personal information.
        • We collect your personal information to promote our services, to provide them, to support them and to develop them.
        • We do not sell your personal information to third party.
      • The categories of third parties with whom the business shares personal information.
        • We share your personal information with our vendors in order to achieve our business purposes (e.g., Amazon, Twilio, Heroku, EasyWP.com, Google, PaperTail)
      • The specific pieces of personal information it has collected about that consumer.
        • Please email us at  privacy@ccpatollfree.com or call us toll free at 1-866-I-OPT-OUT and enter Service Code 1 to request this information. Before we can respond to your request, we’ll need to verify your identity.  
  • A description of a consumer’s rights pursuant to Section 1798.115:
    • If we sell your personal information or that discloses it for a business purpose, you have the right to know:
      • The categories of personal information that the business collected about the consumer.
        • We disclosed this above (e.g., web log data, registration data).
      • The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
        • We do not sell your personal information, so there is nothing for us to disclose in response to this requirement.
      • The categories of personal information that the business disclosed about the consumer for a business purpose.
        • We rely on vendors to operate our infrastructure, and accordingly for each category of personal information that we disclosed above as a category that we collect, we disclose it to one of our third-party vendors for a business purpose (i.e. to develop, market, provide and support our business services). Those categories are: web log data,registration data, payment data, service usage data and marketing data.
    • If we sell your personal information or disclose it for a business purpose, you have the right to request that we disclose to you (1) the categories of personal information that we collected about you, (2) the categories of personal information we sold about you and the categories of third parties to whom we sold it, by category of personal information for each third party to whom we sold your personal information and (3) the categories of personal information that the business disclosed about the consumer for a business purpose. We are required to verify your identity before providing you with this information if the information would constitute your personal information.
      • Because we operate our services consistently for all customers, we have disclosed to everyone as part of our privacy policy the information you are entitled to receive, so there is no need for you to submit a request for this information.
    • If we sell you personal information to a third party or discloses it for a business purpose, we are required to disclose:
      • The category or categories of consumers’ personal information it has sold, or if the business has not sold consumers’ personal information, it shall disclose that fact.
        • We do not sell your personal information.
      • The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, it shall disclose that fact.
        • We rely on vendors to operate our infrastructure, and accordingly for each category of personal information that we disclosed above as a category that we collect, we disclose it to one of our third-party vendors for a business purpose (i.e. to develop, market, provide and support our business services). Those categories are: web log data, registration data, payment data, service usage data, customer content, consumer content and marketing data.
    • If we sell your personal information to a third party, it is not allowed to resell it unless we notified you explicitly and provided you with a chance to opt out.
  • A description of a consumer’s rights pursuant to Section 1798.125:
    • Businesses, including us, may not discriminate against you because you exercised any of your consumer privacy rights such as by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including via discounts or other benefits or penalties; (3) providing you a different level or quality of goods or services or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Businesses may however discriminate where any difference is reasonably related to the value provided to you by your data.
    • Businesses, including us, may offer you financial incentives, including payments as compensation, for the collection, sale or deletion of your personal information. If we offer any incentives we will (1) notify you about them in our privacy policy and in any California-specific descriptions of consumer privacy rights we post and (2) only enroll you in them with you opt-in consent after disclosing all material incentive program terms to you. Incentive programs may never be unjust, unreasonable, coercive, or usurious.
      • We do not currently offer any financial incentives.