CivicPlus is dedicated to adhering to the various state privacy laws to which we and our customers are bound, including the California Consumer Privacy Act of 2018 (“CCPA,”) which became effective on January 1, 2020, and its November 2020 amendment, effective January 1, 2023. In addition, we recognize other states also have data protection and cybersecurity regulations and seek to adhere to their requirements as well, including but not limited to Connecticut, Colorado, Delaware, Indiana, Iowa, Montana, Tennessee, Texas, Utah and Virginia. We provide this U.S. CCPA & State Law Privacy Notice in compliance with those state laws and are committed to reviewing and, if necessary, updating our privacy practices against any new state or federal privacy law that may be enacted in the future.
This Notice at Collection applies to CivicPlus’ activities as a data controller or owner. For the data that CivicPlus processes as a data processor, please see the Product Privacy Notice for the applicable product. For residents who are using our Resident Portal, we direct you to our End User License Agreement for that feature for further privacy-related information regarding how we collect, use, process, and share your resident data, including across municipalities.
CivicPlus is Committed to the Privacy Principles of:
Accountability: We promise to hold ourselves accountable to our Customers and our and their Users who trust us with their Personal Information
Transparency: We promise to be clear and transparent about what Personal Data we collect, how we use it, to whom we disclose it, with whom we share it, and if we sell it (We don’t!)
Control: We believe that Users should have control over what Personal Data we access; should be able to correct any Personal Data that is incorrect; and should be able to delete Personal Data they no longer wish us to have.
Introduction
We base our definition of “Personal Information” on that of the CCPA, which defines Personal Information as such information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular resident and includes certain categories of Personal Information set out in this Notice. Personal Information can also include “Sensitive Personal Information.”
Other capitalized terms used in this U.S. CCPA & State Privacy Notice - Notice at Collection (“Notice”) have those definitions as set out in our Privacy Policy. Use of the CivicPlus Platform requires users to be at least thirteen (13) years of age. We do not knowingly collect Personal Information from anyone under the age of 13. If you believe a child under 13 has provided Personal Information, please contact us at privacy@civicplus.com.
Transparency
We believe in the principle of transparency. This means we will always tell you what Personal Information we collect (the “What”); From what sources we collect Personal Information (the “Where”); Why we collect Personal Information (the “Why”); and with whom we share Personal Information (the “Who.) The Categories of “What” come from the CCPA and related state law. We promise that we will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
General Personal Information
What | Where | Why | Who |
|---|---|---|---|
A. User Identifiers: Name, Title, Company Email, Company Address, Company Phone Number, Affiliated Customer Organization, IP address | Leads; Customers; Interactions with Users |
| Service providers; Customers |
B. Customer Records: Name, Signature, Company Address, Company Phone Number | Prospect leads; Customers; Interactions with affected Users |
| Service providers; Customers |
C. Characteristics of Protected Classifications Under California or Federal Law: Gender identity if provided in a Users’ email signature | Interactions with affected Users | CivicPlus does not categorize or make use of this Personal Information. However, to the extent it is provided by a User through an interaction with CivicPlus, e.g., via an email to CivicPlus sales, marketing, or support services. | Service providers |
D. Commercial Information: Purchase and use of the CivicPlus Services | Users’ interactions with the CivicPlus Services; Customers and Users |
| Service providers |
E. Biometric Data: We do not collect biometric data for identity verification | N/A | N/A | N/A |
F. Internet or other Electric Network Activity Information: Information regarding Users’ use of the CivicPlus Services Cookies and cookieless tracking technologies when Users interact with our website and services | Users’ interactions with the Website |
| Service providers |
G. Geolocation Data: IP address | Users’ interactions with the Website and CivicPlus Services |
| Service providers |
H. Audio, electronic, visual, thermal, olfactory, or similar information: Audio and video | Interactions with affected Users |
| Service providers |
I. Professional or Employment-Related Information: Name, Title, Company Email, Company Address, Company Phone Number, Affiliated Customer Organization | Prospect leads; Customers; Interactions with affected Users |
| Service providers |
J. Education Information: Not collected | N/A | N/A | N/A |
L. AI Interaction Data: Chatbot conversation inputs and outputs, service routing data | Users’ interactions with AI-enabled features on the Platform |
| Service providers |
Sensitive Personal Information
What | Where | Why | Who |
|---|---|---|---|
Account Log-In, Financial Account, Debit or Credit Card Number, and the Means to Access the Account (Security or Access Code, Password, Credentials): Account log-in information; Credentials | Customers and Users |
| Service providers |
Precise Geo-Location Information: IP Address | Users’ interactions with the Website and CivicPlus Services |
| Service providers |
Is any sensitive data processed? | No | N/A | N/A |
Racial or Ethnic Origin, Religious or Philosophical Beliefs, or Union Membership: Not collected | N/A | N/A | N/A |
Medical or Mental Health, Sex Life, or Sexual Orientation: Not collected | N/A | N/A | N/A |
Biometric Data: CivicPlus does not collect biometric data for identity verification | N/A | N/A | N/A |
Contents of your Mail, Email, or Text Messages (where CivicPlus is not the intended recipient of the communication): Not collected | N/A | N/A | N/A |
Personal Data Collected from a Known Child Under 13 Years of Age: Not collected | N/A | N/A | N/A |
Additional Reasons We May Also Collect, Use, or Share Personal Information
In addition to the above, we may also collect, use, or share Personal Information for the following purposes:
Protection: To protect the rights, property, or safety of CivicPlus, our Customers, Users, or others;
Law Enforcement: To respond to law enforcement requests or as may be required by law, court order, or government regulation; or
Mergers and Acquisitions: 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 bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
With Whom We Share Personal Information
We believe that Users have the right to know if their Personal Information is shared with third parties. We may share with or otherwise disclose your Personal Information for the business purposes outlined in this Notice. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
Category A: User Identifiers
Category B: Customer Records
Category C: Characteristics of Protected Classifications Under California or Federal Law
Category D: Commercial Information
Category F: Internet or other Electric Network Activity Information
Category G: Geolocation Data
Category H: Audio, electronic, visual, thermal, olfactory, or similar information
Category I: Professional or Employment-Related Information
To Service Providers. We may provide Personal Information to our services providers, as defined by the CCPA, so that they can perform services for us as specified in our contracts with such service providers and for the purposes outlined above.
Other Purposes. In addition, we may disclose personal information to third parties for other notified purposes, as permitted by U.S. state data privacy laws.
"Sharing" and Personalized Advertising. We do not share Personal Information with third parties for personalized advertising purposes, as defined under applicable U.S. state laws.
We Do Not Sell Your Personal Information
Users have the right to know if their Personal Information is being sold. Personal Information is sold when it is provided to a third party for monetary or other valuable consideration for a purpose that is not considered a business purpose as defined by the relevant state law. This does not include where CivicPlus may share personal data where permitted by law or at a User’s or Customer’s direction. CivicPlus does not sell Personal Information.
In the preceding twelve (12) months, we have not sold any Personal Information.
Right to Opt-out of “Sale” or “Sharing"
CivicPlus does not sell or share your personal information as that is defined by relevant state law. Therefore, we do not offer an opt-out.
Control: Your Rights Under State Law
If you are a covered User under relevant state law, you have the following rights:
Receive this Notice at or before collection of Personal Information.
Request that we disclose to you the following information covering a twelve (12)-month period prior to your request. Such disclosure is free of charge to you:
The categories of Personal Information we have collected about you;
The categories of the sources from which the Personal Information was collected;
The Categories of third parties to whom we disclosed your Personal Information; the categories of Personal Information that were disclosed; and the purpose for disclosing the Personal Information; and
The Personal Information we collected about you.
Request that we correct any Personal Information that we hold that is inaccurate.
Request that we delete Personal Information unless a state law exception to deletion applies (for our own tax reporting obligations)
Be free from unlawful discrimination where you may exercise your rights.
How to Exercise Your Personal Information Rights Under State Law
Users can exercise their Personal Information rights under state law by submitting a request to us using the following methods:
Completing an online Data Subject Access Request
Calling us at +1 888-228-2233
CivicPlus will acknowledge your request and advise you how long we expect it will take us to respond. We must be able to verify your identity. Please note that requests for specific pieces of Personal Information may require additional information for this verification. Individuals or Customers who submit a request on behalf of another person must provide us with proof of authorization and verification directly from the person to whom the request relates.
We may not be able to honor all requests, in some circumstances. For example, if we cannot verify a requestor’s identity or authorization. We also will not honor requests where an exception applies. Where we cannot honor a request, we will advise you.
We will respond to all requests within the time frame required by law. For California residents, this is 45 days. If we need additional time, up to 45 additional days, or as allowed under relevant law, we will provide you with an explanation for the delay. We will need up to 90 days to complete: Any compounded requests (such as a request to access data and a secondary request to delete the identified data); and any request related to services that require us to work with a service provider or third-party to complete the request
Notwithstanding the foregoing, please note that since our customers, and not CivicPlus, are the “Data Owners” per the terms of the CCPA, we cannot respond directly to requests from our customers’ “Data Subjects” (resident end-users).
To accommodate Data Subject requests, we will direct all incoming Data Subject requests to the appropriate municipal representative. In these instances, the municipal Data Owner is responsible for determining whether or not to respond to a Data Subject’s CCPA-related request. As part of this determination process, we highly recommend that you discuss the following scenarios with your legal counsel:
As a public entity, is your municipality required to comply with the request?
Are there any applicable state or local laws that preempt or limit your ability to comply?
Have you validated the identity of the requesting Data Subject?
How to Contact Us Regarding This Notice
Mail: CivicPlus, LLC, Attention: Legal, 302 S. 4th Street, STE 500, Manhattan, Kansas, 66502
Email: privacy@civicplus.com (privacy matters) or support@civicplus.com (general Platform support)
Telephone: +1 888-228-2233
Changes to This Notice
From time to time, we may need to update this Notice to reflect changes in our data practices as we are committed to full transparency or if there is a change in the law that requires an update. When we need to make such an update, we will email registered Users at the email address we have on file. So as not to miss any important updates to this Notice, we ask Users to exercise their right to update the email address they have given us. For changes that materially affect your privacy rights, we will also endeavor to notify you through the Platform at least thirty (30) days before such changes take effect, consistent with our Terms of Use.