This page was created to provide you with information about the CCPA and the ways in which OpenWeb complies with its current requirements.
CCPA – what is it all about?
The California Consumer Privacy Act of 2018 (CCPA) – which came into effect on January 1, 2020 – consists of a series of legislative bills that gave new privacy rights to consumers residing in the State of California, and imposed obligations on businesses processing their personal information.
Due to the fact that the bills were signed in October 2019, the California Attorney General didn’t have the opportunity to finalize its Proposed Regulations before the CCPA came into effect – so on January 2020 it provided a “grace period” and announced that CCPA enforcement will only commence on July 1, 2020.
OpenWeb is dedicated to comply with the requirements of the CCPA and the AG’s Proposed Regulations, in light of similar regulations worldwide (such as the GDPR) and evolving industry standards – to ensure that our partners and users may continue using our services without interruption.
Roles, responsibilities & exemptions
The CCPA distinguishes between three roles for companies involved in the processing of personal information:
- Business (similar to ‘controller’ under the GDPR)
- Service Provider (similar to ‘processor’ under the GDPR)
- Third Party (similar to a Business, but one that does not have a direct interaction with the consumer)
The obligations imposed on ‘Businesses’ outline the limits of ‘sale’ of personal information and define specific actions that Businesses are required to perform, including:
- Place a “Do-Not-Sell-My-Personal-Information” button on their homepage;
- Inform consumers of categories & specific pieces of their personal information collected/sold;
- Provide at least 2 methods of communications for requesting to exercise consumer privacy rights.
The CCPA currently only applies to ‘consumers’ (and not ‘Data Subjects’ as more broadly defined under the GDPR), and certain relationships were exempt from CCPA enforcement (pending additional debate) until at least January 1, 2021:
- Employee information (this includes past, current and potential employee information)
- B2B interactions (information obtained in the course of an activity between companies)
To learn more, visit:
- ‘Californians for Consumer Privacy’ – informational website by the movement that pushed to the creation of the CCPA
- Xavier Becerra – California’s Attorney General webpage.
What is OpenWeb’s role under the CCPA?
There are two ways in which OpenWeb might access and process your information:
(1) Integration via Single-Sign-On (SSO) – when you log in to your account at a certain website, the publisher of such website shares with us your registration information (usually name & email, without any passwords of course);
In such cases, OpenWeb will act as a Third Party who processes consumer information on behalf of the publisher, the Business. Due to the nature of our services and our efforts to create a community free of hate speech or toxic behavior, certain parts of the information shared with us (e.g. your IP address) may be used to help promote the safety and growth of our community.
(2) Direct signup – prior to posting your first comment via our service, you may sign-up to our service, either by submitting your name, e-mail and (hashed) password, or by connecting your social media account (in which case you will also share with us your public profile picture(. In such cases, OpenWeb will act as a Business who processes consumer information alongside the publisher, who will be acting as Business as well. Due to the nature of our services, certain requirements of the CCPA will only be accessible via our conversation widget, rather than our own website (such as the “Do-Not-Sell-My-data” button).
Why & What does OpenWeb do with your Personal Information?
We collect personal information for the following purposes:
Personalization – To provide and operate our services, to verify and authenticate our users, and to provide our users with a personalized user experience (for example: suggesting content that is relevant to you based on your past interests).
Advertising –Some of our partners use our services to gain an additional adverting-based revenue stream, and use personal information such as IP address and advertising ID to provide you with better and personalized advertising experience.
Service Improvement, Research & Analytics –We use aggregated, non-identifiable user information to further develop, customize and improve our service based on common preferences and uses, as well as for statistical and research purposes both for our internal use and for the use of our partners.
Security and Protecting Rights –We may use and disclose your personal information (e.g. IP address) to investigate violations and enforce our & our partners’ policies for free speech, to reduce fake news and avoid spam and malicious behavior. Communications –We may use your information to communicate with you – for example, we will use your contact details to respond to your queries or feedback, and to provide you with technical assistance and support.
Your rights under the CCPA
The CCPA provides Californians with the following rights:
Requests for information
please see the instructions below on how to receive a copy of your personal information from our conversation extension:
Your Right to Opt out of Sales
We enable users from the State of California to exercise their right to request that we do not “sell” their personal information. In OpenWeb’s case, this will only apply to the use of targeted advertising, and once we receive and verify that the request is valid and indeed filed by a California resident, we will take steps to refrain from providing them with targeted, personalized ads (note however that this does not mean that we will not show ads at all).
To update your AdChoices Opt Out settings, select your region here.
Your Right to Notification
Nondiscrimination for exercising your CCPA Rights
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Needless to say, OpenWeb will never discriminate against you for choosing to exercise your rights.
Your Right to Delete Personal Information
Follow the instructions below to permanently delete your personal information from our system:
Please be advised that due to the nature of our services, when requesting to delete your information from SSO integrated partners/publishers, you will need to submit your request directly with the selected partner prior to exercising your right with us.
Our Data Protection Officer (DPO), Mr. Aner Rabinovitz of PrivacyTeam, is your point of contact for any privacy related questions or concerns. Aner may be reached at firstname.lastname@example.org or directly at email@example.com.
We are following the constant developments in the legislative and regulatory process surrounding the CCPA (as well as other applicable state / federal / global privacy laws), and engage in regular ‘benchmarking’ in light of emerging industry practices and standards.
This Document was last updated on: June 22, 2020.