Comet CCPA Privacy Notice

For the purposes of this notice, Personal Information means 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, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

• Lawfully made available from government records.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Examples: Name, postal address, online identifier, internet protocol address, email address, social security number, driver’s license number, passport number, or other similar identifiers. 

Examples: Name, social security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Examples: age (over 40).

Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. 

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement. 

Example: Precise physical location. 

Examples: Social media profile images.

Examples: Job application or resume information, past and current job history, and job performance information.

Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.  

Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

1. Providing Services: Providing our services.
2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
3. Sending Messages: Sending you text messages or push notifications.
4. Facilitating Payments: Facilitating transactions and payments.
5. Deidentification and Aggregation: De-identifying and aggregating information collected through our services and using it as indicated in our Privacy Policy.
6. Job Applications: Processing your job application.
7. Safety Issues: Responding to trust and safety issues that may arise.
8. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
9. Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions.
10. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
11. Debugging: Debugging to identify and repair errors that impair existing intended functionality.
12. Transient Use: Short-term, transient use.
13. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling testing and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
14. Research: Undertaking internal research for technological development and demonstration.
15. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
16. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
17. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources: 

1. You/Your Devices: You or your devices directly.
2. Users: Other users of our services.
3. Employers: A party that has engaged or employed you.
4. Analytics Providers.

Disclosure of Personal Information 

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties: 

1. Analytics Providers.
   • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Internet or Other Electronic Network Activity Information.
2. Vendors: Vendors and service providers.
   • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, and Characteristics of Protected Classifications under California or Federal Law.
3. Third Parties as Legally Required: Third parties as required by law and similar disclosures.
   • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, and Characteristics of Protected Classifications under California or Federal Law.
4. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
   • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, and Characteristics of Protected Classifications under California or Federal Law.
5. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information. 
   • Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Sensory Information, Professional or Employment-Related Information, Inferences Drawn from Personal Information, and Characteristics of Protected Classifications under California or Federal Law.

If you are a California resident, you may exercise the following rights. 

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months. 

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. 

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.  To verify your access or deletion request, please provide us with your name, email address, and phone number associated with your account, and we will let you know if we need any additional information to verify your request.

Right to Opt Out. In some circumstances, you may opt out of the sale of your Personal Information. We do not sell your Personal Information. 

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. 

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please email us at privacy@comet.ml or write us at Comet ML, Inc., 228 Park Ave S, Suite 15549, New York, NY, 10003, Attn: Privacy Officer. 

Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please email us at privacy@comet.ml and attach a written authorization signed by the resident.

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at privacy@comet.ml or write to us at:

Comet ML, Inc.
228 Park Ave S
Suite 15549
New York, NY, 10003 
Attn: Privacy Officer