CCPA Addendum to Privacy Policy

Last Updated: October 15, 2024

The California Consumer Privacy Act of 2018 (as amended from time to time, “CCPA”) requires businesses that collect personal information of California residents to make certain disclosures regarding how they collect, use and disclose such information. This CCPA Addendum to the ManageXR Privacy Policy (the “Privacy Policy”) addresses those requirements.  Capitalized terms used herein and not otherwise defined shall have the respective meanings provided in the ManageXR Privacy Policy or under CCPA. For a description of all of our data collection, use and disclosure practices, please read the ManageXR Privacy Policy in its entirety.  If any terms in this Addendum conflict with other terms contained in the Privacy Policy, the terms in this Addendum shall apply to Individual Users that are California residents.

Please also note that this CCPA Addendum only applies to Personal Information of California residents that we collect in connection with ManageXR’s website and marketing activities.  If you are a company or business to whom we provide our ManageXR Platform and related services (or the employees, representatives or other end users of such companies or businesses), this Addendum does NOT apply to you.  Please visit instead our Data Processing Addendum, for more information related how we handle information collected from California residents related to the ManageXR Platform and our related customer services.

1. Personal Information Collection and Sharing:  ManageXR collects User Information as set forth in our Privacy Policy and this CCPA Addendum shall apply to all such User Information of California residents that qualifies as “Personal Information” as defined by CCPA, with such CCPA-specific User Information being referred to herein as “Personal Information”.  For purposes of CCPA, we collect the following categories of Personal Information from you when you interact with us and we share that Personal Information for business purposes as follows:

Categories of Personal Information We Collect	Categories of Third Parties with Which We Share Information for Business Purposes
Identifiers (such as name, address, email address)	Vendors, service providers and third party business partners
Any categories of Personal Information described in subdivision (e) of Section 1798.80 of the CCPA (such as address, telephone number, financial information)	Vendors, service providers and third party business partners
Internet or Other Network or Device Activity (such as browsing history and interaction with the Site)	Vendors, service providers and third party business partners
Approximate Location Information (such as location inferred from your IP address, city, country)	Vendors, service providers, and third party business partners
Professional or Employment-Related Data (such as the name of your employer)	Vendors, service providers and third party business partners
Education Information (such as degrees and certifications)	Vendors, service providers and third party business partners

2. Sources and Uses of Personal Information: The sources from which we collect Personal Information are described in Sections 4 and 5 of the ManageXR Privacy Policy. 

3. Purposes and Uses for Collecting Personal Information: We collect Personal Information identified in the list above to communicate with you, for marketing and promotional purposes, to  Interact with you, to provide and improve our Services and other purposes set forth in Sections 6 and 7 of the ManageXR Privacy Policy.

4. Subprocessors.  We may use third party service providers (known as subprocessors) to facilitate use and operation of the Site and/or for other activities related to our Interactions with you and our other business activities.  We share some personal data with these subprocessors to help us provide, manage, secure and improve the Site and our Interactions with you. Your Personal Information may be provided to and used by such subprocessors in furtherance thereof.  A current list of our third party subprocessors is available here.  Our subprocessors have privacy and security practices in place to ensure compliance with CCPA and have contractual requirements to protect the privacy and security of the personal data that they sub-process. 

5. Sale of Personal Information.  We do provide certain Personal Information to third party service providers and analytics platforms for our analytics purposes and in connection with marketing and promotion.  For instance, we may use your Personal Information to engage in targeted advertising and marketing efforts on LinkedIn, Google and Meta.  As set forth in our Privacy Policy, we may also provide information to our third party partners for their business and commercial purposes.

6. California Consumer Rights: California law gives California residents the right to make the following requests with regard to certain information we collect about them, at no charge, two times every 12 months:

• Disclosure Right.  The right to request disclosure of our data collection and sales practices, including categories of information we have collected, the source of the information, our use of the information and, if the information was disclosed or sold to third parties, the categories of Personal Information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold.
• Copy Right.  The right to request a copy of the specific Personal Information we collected about you in the past 12 months.
• Deletion Right.  The right to request deletion of Personal Information we have collected, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation, and where the Personal Information is being used on an anonymized and aggregated basis consistent with the requirements of the CCPA). 
• Opt-out Right.  The right to opt-out of the sale of your Personal Information, if applicable.  Please visit our page at Do Not Sell My Personal Information to do this.  We do, however, share your Personal Information as we have described in our Privacy Policy and this CCPA Addendum.
• Non-discrimination Right.  The right not to be discriminated against when exercising any of these rights.

7. Exercising Your Rights:  You can submit a copy, deletion, correction or right-to-know request online by emailing as at support@managexr.com. Please include your name and email address with your request. Before we can process any such request, we will need to verify your identity through the email address or telephone number associated with you based on our records, and confirm your request prior to fulfilling any such request and reserve the right to deny a request where we are unable to satisfactorily complete this process. If you authorize someone to make a request on your behalf, we may also deny your request if we are unable to verify that the individual making the request is authorized to act on your behalf.  ManageXR does not and will not discriminate against you for exercising your rights under the CCPA.