ADDITIONAL INFORMATION REGARDING CALIFORNIA

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information about California residents that we collect, use or disclose.  Under the CCPA, “Personal Information” is information that identifies, relates to, describes, or could reasonably be associated or linked with a particular California resident or household.   We are providing this Privacy Policy in addition to the information contained in our general [AHAB Privacy Policy].

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Collection of Personal Information

We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information, as listed in the CCPA:  

1. “Identifiers.” Identifiers, such as name, alias, contact information, unique personal identifiers and online identifiers;
2. “Customer Records Information.”  Personal information as defined in the California customer records law, such as financial account number and employment information;
3. “Protected Class Information.”  Characteristics of protected classifications under California or federal law, such as sex;
4. “Transaction Information.”  Commercial information, such as transaction information and purchase history;
5. “Online Use Information.”  Internet or network activity information, such as browsing history and interactions with our website;
6. “Geolocation Data.”  Geolocation data such as device location and approximate location derived from IP address;
7. “Audio/Video Data.”  Audio, electronic, visual, and similar information, such as audio recordings;
8. “Employment Information.”  Professional or employment-related information, such as audio credits and work history; and
9. “Inferences.”  inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Where We Obtain Personal Information From

As described above, we collect this Personal Information from you, from other Ahab users such as Talent, Agents and Producers, and from data analytics providers. 

Our Use of Personal Information

As described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

Disclosure of Personal Information

We share Personal Information with the following categories of third parties:

• “Affiliates.”  We share with our affiliates for the purposes described in this Privacy Policy.
• “Service Providers.”  We share with our trusted third-party service providers, to facilitate services they provide to us, such as internet services, website hosting, data analytics, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, background checks, and other services. 
• “Other Ahab Users.”  Such as Talent, Agents and Producers
• “Legal Authorities.”  We share with public and government authorities, including regulators and law enforcement, to respond to requests, as well as to protect and defend legal rights.
• “Other Parties in Litigation” We share information in the context of litigation discovery and in response to subpoenas and court orders.

In the preceding 12 months, we disclosed for our operational business purposes the following categories of Personal Information to the following categories of third parties:

Categories of Personal Information	Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers	Payment System, Analytics, Direct Marketing
Customer Records Information	Payment System, Other Ahab Users
Protected Class Information	Other Ahab Users, Analytics, Direct Marketing
Transaction Information	Payment System, Analytics, Direct Marketing
Online Use Information	Analytics, Direct Marketing
Geolocation Data	Payment System, Analytics, Direct Marketing
Audio/Video Data	Other Ahab Users, Analytics, Direct Marketing
Employment Information	Other Ahab Users, Analytics, Direct Marketing
Inferences	Analytics, Direct Marketing, Other Ahab Users

We do not “sell” and have not “sold” Personal Information for purposes of the CCPA in the last 12 months.  We do not sell the Personal Information of minors under 16 years of age.

Your CCPA Rights

Requests to Know and Delete If you are a California resident, you may request that we:

“Request to Know”

1. Disclose to you the following information covering the 12 months preceding your request:
   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting Personal Information about you; and
   • The categories of Personal Information about you that we otherwise shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

“Request to Delete”

2. Delete Personal Information we collected from you.

To make a Request to Know or Request to Delete, , please contact us in accordance with the “Contacting Us” section above.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  Alternatively, we may send our response to your request to the contact point in our records that is associated with the Personal Information that is requested.  If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information.

If you are the authorized agent of a consumer, making a Request to Know or a Request to Delete on behalf of the consumer, we will ask you for:

         1. proof of your registration with the California Secretary of State to conduct business in California.

         2. proof that the consumer has authorized you to make a Request to Know or a Request to Delete on the consumer’s behalf.  This must be a permission signed by the consumer. “Signed” means that the permission has either been physically signed or provided electronically in accordance with the Uniform Electronic Transactions Act, Civil Code 1633.7 et seq.

If an authorized agent has not provided us with a power of attorney from the consumer pursuant to Probate Code sections 4000-4465, we may also:

1. require the consumer to provide you with a written permission signed by the consumer to make the request on the consumer’s behalf

2. verify the identity of the consumer as we would if the consumer were making the request personally.

3. Obtain verification from the consumer that they provided the authorized agent permission to make the request.

Right to Non-Discrimination

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Your Right To Request Removal of Content

Pursuant to California Business & Professions Code section 22581, if you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to  privacy@penguinrandomhouse.com (U.S)
dataprotection@penguinrandomhouse.com (International) .  Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.