Last updated: November 25, 2023

The NetNubby Service neither 1) generated annual gross revenue in excess of $25 million during the preceding calendar year; 2) derives over 50% of its annual revenue (which revenue is not limited to revenue generated only in California or from California residents) from selling¹ or sharing² consumers’³ personal information⁴ (including “sensitive personal information”⁵); nor 3) alone or in combination annually buys, receives, sells, or shares the personal information of more than 100,000 consumers, households or devices for commercial purposes.

If you are an account holder residing in California, you understand you have no rights under the law regarding our Service because this Act does not apply between us: We are not a “business” per CCPA Section 1798.140(c)(1)

The California Privacy Rights Act (CPRA) amended the CCPA in part by adjusting its thresholds (listed supra). Again, because the CCPA is not binding between us, neither is the CPRA.

Further, please know that under CCPA exemptions, we may be allowed to “collect, use, retain, sell or disclose consumer information” that is deidentified or aggregated.

¹ In the CCPA this means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating… a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”

² This means “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating… a consumer’s personal information by the business to a third party for cross‐context behavioral advertising, whether or not for monetary or other valuable consideration… .”

³ A “consumer” is “a natural person who is a California resident.”

⁴ Personal information includes “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.”

⁵ This is a sub-category of “personal information” and includes government identifiers, precise geolocation, information concerning sexual orientation, racial or ethnic origin, religious or philosophical beliefs, union membership, citizenship and immigration status.