CCPA & VCDPA Notice

This notice sets out the rights of residents of California (CCPA as amended by the CPRA), Virginia (VCDPA), and the other US states with comprehensive privacy laws — including Colorado, Connecticut, Utah, and Texas — whose rights are broadly the same. It supplements the Privacy Policy.

1. What we collect, and why

In the last 12 months we have collected these categories of personal information:

• Identifiers — name, work email, employer, job title, IP address. Purpose: to provide the service and to supply B2B contact data. Sources: our customers, public web sources, licensed providers.
• Commercial information — subscription and billing records. Purpose: to bill you.
• Internet activity — pages visited, device and browser data. Purpose: to operate, secure, and improve the site.
• Professional information — job title, seniority, department, employer. Purpose: B2B prospecting data.

We do not collect sensitive personal information as the CPRA defines it, and we do not use or disclose it for inferring characteristics.

2. Sale and sharing — the honest answer

We do not sell our customers' personal information, and we never sell the data you upload.

But the CCPA/CPRA definitions of "sell" and "share" are deliberately broad, and our B2B contact database is made available to customers for valuable consideration. We therefore treat that as a sale and/or share of personal information, and we disclose it as such rather than relying on a narrow reading that suits us.

Categories sold or shared: identifiers and professional information. Recipients: our subscribing customers. We do not knowingly sell or share the personal information of consumers under 16.

Do Not Sell or Share My Personal Information

3. Your rights

• Know — what we collect, why, where it came from, and who we disclose it to.
• Access — a copy of the specific pieces of personal information we hold about you.
• Delete — subject to the narrow exceptions the statutes allow.
• Correct — inaccurate personal information.
• Opt out — of the sale or sharing of your personal information, and of targeted advertising.
• Limit — the use of sensitive personal information (we do not collect any, so there is nothing to limit).
• Non-discrimination — we will never charge you more, give you less, or degrade your service because you exercised a right.
• Appeal (Virginia and several other states) — if we refuse a request, you may appeal it; see below.

4. How to exercise them

Two ways, both free:

• Use the Do Not Sell or Share form — for opt-outs, this requires nothing but an email address. No account, no identity verification.
• Email legal@govarova.com for access, deletion, or correction requests.

For access and deletion we may need to verify that the request is really yours, because handing your data to the wrong person would be worse than not handing it over at all. We verify by matching the request against information we already hold — never by asking you for more sensitive data than we already have.

5. How long we take

Opt-out of sale or sharing: within 15 business days. Access, deletion, and correction: within 45 days, extendable once by a further 45 days where the request is complex, in which case we will tell you.

6. Authorised agents

You may use an authorised agent. We will ask for written proof of their authority, and for verifiable requests we may still need to verify your identity directly.

7. Global Privacy Control

We honour the Global Privacy Control (GPC) browser signal as a valid opt-out of sale and sharing for the browser that sends it, as California requires. Because a browser signal cannot identify you across devices, use the form as well if you want the opt-out applied to your email address everywhere.

8. Appeals

If we decline a request, we will tell you why. To appeal, reply to that decision or email legal@govarova.com with "Appeal" in the subject. We will respond within 60 days. If we deny the appeal, you may contact your state Attorney General.

9. Contact

All US privacy requests: legal@govarova.com.

Randoye LLC, a Wyoming limited liability company, trading as Govarova.
30 N Gould St, Ste 5275
Sheridan, WY 82801
United States
legal@govarova.com

We are a fully remote company. The address above is our registered address for legal correspondence; we do not operate a public office and cannot receive visitors.