Privacy Hub: POV – fullthrottle.ai

fullthrottle.ai knows that you care how information about you is used and shared, and we appreciate your trust that we will do so responsibly. This Privacy Hub page provides knowledge, links, and educational materials related to the latest privacy policies in effect - and also outlines our interpretation, implementation, and execution of these rules and regulations.

By visiting our website at “https://www.fullthrottle.ai/” and other domain names managed by fullthrottle.ai, and using our products and services, you are accepting the practices described in our Privacy Policy, and consent to fullthrottle.ai's Terms of Use.

OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION

fullthrottle.ai will not sell any of your information, but under certain circumstances we may share your Personal Data as follows:

Affiliated Companies: We may also share your Personal Data with our affiliated companies for purposes consistent with this Privacy Policy.
Agents, Consultants and Other Service Providers: From time to time fullthrottle.ai hires other companies to perform certain business-related functions or work for us to provide our products and services to you. These companies may include Email automation services, hosting and cloud computing service providers, customer service, website analytics companies, and marketing and sales software solutions. We only give them with the limited information that they need to perform the specific task they are hired to do. Subject to our specific instructions, they may access, process or store Personal Data solely in order to perform the services we have hired them to do.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your Personal Data may be part of the transferred assets.
Legal Requirements: fullthrottle.ai may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of fullthrottle.ai, (iii) act in urgent circumstances to protect the personal safety of users of our website or our products or services or the public, or (iv) protect against legal liability.

STATE DATA PRIVACY INITIAVES

fullthrottle.ai complies with state data privacy laws.

California Consumer Privacy Act of 2018 (CCPA)
- Effective date = January 1, 2020

California Consumer Privacy Rights Act (CPRA)
- Effective date = January 1, 2023

Colorado Privacy Rights Act (CPRA)
- Effective date = July 1, 2023

Virginia Consumer Data Protection Act
- Effective date = January 1, 2023

Utah Consumer Privacy Act
- Effective date = December 31, 2023

Connecticut's “Act Concerning Personal Data Privacy and Online Monitoring”
- Effective date = December 31, 2023

Nevada Privacy Law (Senate Bill 220)
- Give consumers the right to opt-out of the sale of their personal information to third parties

New York Stop Hacks and Improve Electronic Data Security Act (SHIELD Act)
- Covers breaches of certain personally-identifiable computerized data

Vermont Security Breach Notice Act
- Covers data breach notification requirements for data collectors

CONSUMER RIGHTS

Generally, the intentions of the Acts are to provide State residents with the:

RIGHT TO NOTICE

Businesses must provide notice at or before data collection of (1) categories of personal information to be collected, (2) the commercial purpose for which it will be used, and (3) link to the business’ privacy policy

RIGHT TO KNOW

Consumers have the right to know what personal information a business collects, uses, discloses, and sells

RIGHT TO DELETE

Consumers have the right to request deletion of their personal information collected or maintained by a business
- But the states differ in certain respects, including their scope
- CA and UT provide that consumers have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer
- VA and CT provides that consumers have the right to delete personal data provided by or obtained about the consumer
- CO provides that consumers have the right to delete personal data concerning the consumer

RIGHT TO OPT-OUT OF SALE

Consumers have the right to direct a business to no longer sell their personal information. But the states differ in certain respects, including their scope
- CT, CO: Sale of personal data generally means the exchange of personal data for monetary or other valuable consideration by the controller to a third party
- VA, UT: Sale of personal data generally means the exchange of personal data for monetary consideration
- CA: "Sale of personal data" generally means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.”
  - Note that the exchange of money is not required for CA, CT, and CO

RIGHT TO NON-DISCRIMINATION

Consumers have the right not to receive discriminatory treatment for exercising any of their rights

RIGHT TO OPT-OUT OF SHARING (California only)

Businesses that “share” personal information with a third parties that are engaged in cross-context behavioral advertising must provide consumers with the ability to “opt-out” of the sharing

Data Privacy Laws Overview

	California	Virginia	Colorado	Utah	Connecticut
Effective	CPRA fully effective Jan 1, 2023	Jan 1, 2023	July 1, 2021	Dec 31, 2021	July 1, 2023
Private Right of Action	✓	x	x	x	x
Notice At/Before Collection	✓	✓	✓	✓	✓
Opt-in Default for Sensitive Personal Information (SPI)	x	✓	✓	x	✓
Consumer Rights	✓	✓	✓	✓	✓
Employee and B2B Contact Rights	✓	x	x	x	x
Data Governance Requirements	✓	✓	✓	x	✓
Vendor Contract Requirements	✓	✓	✓	x	✓

Consumer Rights

	California	Virginia	Colorado	Utah	Connecticut
Know / Access	✓	✓	✓	✓	✓
Correction	✓	✓	✓	x	✓
Deletion	✓	✓	✓	✓	✓
Restrict Sensitive Personal Information (SPI) Processing	✓	✓	✓	✓	✓
Opt-Out of Sales/Sharing/Targeted Advertising	✓	✓	✓	✓	✓
Opt-Out of Sales/Sharing/Targeted Advertising for Minors	✓	✓	✓	✓	✓
Opt-Out of Profiling/Automated Decision-making	✓	✓	✓	x	✓
Non-Discrimination	✓	✓	✓	✓	✓

U.S. PRIVACY LAWS

Note - the US does not have a federal-level general consumer data privacy law.

U.S. Privacy Act of 1974
- Restricts data held by government agencies

Gramm-Leach-Bliley Act (GLBA)
- Protects financial nonpublic personal information

Health Insurance Portability and Accountability Act (HIPAA)
- Personal healthcare and health insurance data protection

Children’s Online Privacy Protect Act (COPPA)
- Personal information for those under 12

Federal Trade Commission Act of 1914

PERSONAL INFORMATION

Different laws define personal information in different ways. However, CA, CO, VA, UT, and CT have similar definitions

“Personal data” means any information that is linked or reasonably linked to an identified or identifiable natural person

Broad definition
Examples include identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

Non-sensitive information can be personal

Does not include de-identified data or publicly available information

SENSITIVE PERSONAL INFORMATION

In short, sensitive personal information means personal information that reveals certain information about a consumer
Different laws define sensitive personal information in different ways. Here, CA, CO, VA, UT, and CT have different definitions:
- CA, CO, VA, UT, and CT define sensitive information as personal data that includes data revealing racial or ethnic origin, religious beliefs, physical or mental health diagnosis, sexual orientation, or citizen or immigrant status, as well as processing of genetic or biometric data for identification, precise geolocation data, and personal data collected from a known child
- CA also includes information that could be used to commit fraud and identity theft (e.g., Social Security number, driver’s license, state identification card or passport numbers, account log-in, financial account, debit card or credit card numbers in combination with any required security or access code, password or credentials allowing access to an account)

OPT-IN VS OPT-OUT

Whether personal information is “sensitive personal information” triggers whether opt-in consent or an opportunity to opt-out is required

OPT-IN: VA, CO, and CT require that controllers obtain opt-in consumer consent to process sensitive data
OPT-OUT: UT and CA require that controllers must only provide notice and an opportunity to opt-out prior to processing consumer's sensitive

CHILDREN

fullthrottle.ai does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the website or products and services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the website or products and services without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to fullthrottle.ai through the website or products and services, please contact us as indicated in the Contacting fullthrottle.ai section at the end of this document, and we will endeavor to delete that information from our databases.

TRAINING AND TOOLS

The fullthrottle.ai team is committed to staying up to date on the latest privacy rules and regulations. Each department undergoes quarterly privacy training through course leads by general counsel and third party experts and educators.

We are also fully integrated with privacy tools, such as OneTrust LLC.