California Consumer Privacy Act Policy

Effective Date: June 26, 2020

This California Consumer Privacy Act (“CCPA”) Policy (“CCPA Policy”) is incorporated into Two Six Labs’ (“TwoSix”) general privacy policy available here [link] and applies to the personal information of California residents using our website and services (“Consumers,” “you,” or “your”).  For purposes of the CCPA, personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

In the event of a conflict between this CCPA Policy and any of our other privacy policies, this CCPA Policy shall control only with respect to Consumers and their personal information.

Information Collected and Sources

TwoSix collects personal information from you when you interact with us online through our website www.twosixlabs.com (“Site”) or offline. This includes information that you provide to us directly, information we collect from you automatically, information that we collect when you interact with us such as through your online postings, and information that we may collect from third parties such as service providers, affiliated companies, marketing or data partners, or other third parties with whom you interact. It also includes information that we collect about employees and business partners and vendors from those individuals directly or from references, referrals or consumer reporting agencies. Not all information is collected from everyone who interacts with us.

During the past 12 months, we may have collected the following categories of personal information:

  • Identifiers such as contact information (your name, address, phone number, email or postal address), Unique Personal Identifiers (that may include but are not limited to your legal name or preferred alias and online identifiers like user account names), an encrypted version of your password, or communications. We may collect additional information from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses, and titles.
  • Sensitive information such as financial and payment information like your credit or debit card information or PayPal account email address.
  • Commercial information such as your transaction histories, billing and shipping information, and product preferences.
  • Electronic network activity information such as the internet protocol (IP) address collected from your computers and mobile devices and information about what you do online, including your interactions with our Site, through the use of cookies and similar technologies, system logs, and analytics monitoring.
  • Inferences we make about you or your interests based on analysis of other information we have collected.
  • Geolocation information.
  • Audio or video information such as call center recordings or monitoring records from our customer support centers and security video recordings at our facilities.
  • Employment, education and professional related information, protected classification information, or biometrics (collected from current and prospective employees, contractors, service providers, vendors, and suppliers).
  • Other types of personal information that we may disclose to you prior to the point of first collection.

Business Purposes for Collecting Personal Information

TwoSix collects personal information in order to operate and grow our business, improve our Site, and to offer our third-party products or services that we think you may find of interest.  More specifically, we collect personal information for the following business purposes:

  • Provide the Services and information you have requested from us and notices relating thereto, including providing customer and technical support for the Services and collecting fees or other amounts owed in connection with the Services.
  • Verify that you qualify as a registered user of the Services.
  • Provide information to you about our products or services and third-party products and services that we think may be of interest to you.
  • Provide you with marketing communication and information.
  • Analyze, improve, and customize the Services including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.
  • Administer the website, web platform, and Services for internal operations, including troubleshooting, data analysis, testing, research, security, statistical, and survey purposes.
  • Respond to your inquiries about posted job positions and evaluate employment applications.
  • For legal and compliance reasons, such as the prevention, detection, or investigation of a crime, loss prevention, or fraud.
  • Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

Disclosing Personal Information

We may reveal information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g. to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g. in the event that substantially all of our assets are acquired by another party, customer information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g. analyzing data, providing marketing assistance, providing professional legal or accounting services, providing customer service, processing orders, etc.); or (6) as otherwise described in this Privacy Policy.

Information Shared for a Business Purpose

During the past 12 months, we have disclosed the following categories of personal information to the following types of third parties for a business purpose:

  • Our affiliated companies: We may have shared your information such as identifiers, commercial information, and inferences within our company and our affiliated companies for the purposes of decision making, reporting, management, analysis, administering programs, promoting service offerings, and other business purposes.
  • Service providers: We may have shared your information such as identifiers, commercial information, and financial information with our service providers who provide us support services such as hosting our Site, processing payments, legal and accounting professional services, postal delivery and electronic mail, mobile messages, product delivery, conducting analysis to improve our products and Site, fulfilling requests you make, managing payments, and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we don’t allow them to retain, use, or otherwise handle the data for their own purposes.
  • Marketing Partners: We may have shared your information such as electronic network activity, identifiers, commercial information and inferences with marketing partners to display online, mobile or other advertising based on your activity on websites and mobile apps, and preferences you share with us so we can provide you with promotions and special offers that may interest you. We may also share information with marketing partners to help us analyze data, sometimes combined with other sources, so that we can send more relevant communications to you.
  • With Third Parties, including governmental authorities and law enforcement, for legal or compliance purposes: We may share any or all categories of your information where we believe the disclosure is required by law or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies or protect or defend the rights and property of our customers, the company, our partners, or the public (including for fraud prevention purposes).

Selling Personal Information

We do not sell your information for monetary or any other valuable consideration.

Your CCPA Rights

Verified California residents have the right to:

  • Request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
  • Request and receive a copy of the personal information we have collected about them during the prior 12 months.
  • Request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
  • Request that we not sell personal information about them and
  • Request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

In order to make a request for disclosure, California residents may contact us by either by calling (703) 543-9662 or emailing us at info@twosixlabs.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be.  We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. Please understand that we cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to two times within a 12-month period. You may make a request for deletion of your information at any time.

For requests for a copy of the personal information we have collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. For example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud, or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.

We will not discriminate against you as a result of your exercise of any of these rights.

Using an Authorized Agent 

You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us, and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

Contacting Us

If you have questions or concerns, please contact us by phone at (703) 543-9662, emailing us at info@twosixlabs.com, or by postal mail at Two Six Labs, 901 N. Stuart Street, Suite 1000, Arlington, VA 22203.