California Privacy Rights Notice
Effective Date: March 31, 2026 Last Updated: March 31, 2026
The Ativion Group is a group of subsidiary companies of Impala Bidco and forms part of the Ativion and ContentKeeper companies as defined in our Group Structure available at www.ativion.com/legal/group-structure (referred to herein as “Ativion”, “us”, “we”, “ours”). Ativion operates services, including websites, software, technologies, services, support services, applications, and accounts. Ativion is committed to respecting the privacy of information and data of the users of our applications and other individuals (“you”). This California Privacy Rights Notice applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. Any other capitalized but undefined terms have the same meaning found in the Privacy Policy.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | 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. | Yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, 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. Some personal information included in this category may overlap with other categories. | Yes |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) | No |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Yes |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| G. Geolocation data. | Physical location or movements. | Yes |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Yes |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes |
| K. Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes |
| L. Sensitive Personal Information | Social security numbers, driver’s license, state identification card, passport number, financial account login in combination with security or access code, password or credentials, or precise geolocation. | No |
Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as health or medical information covered by HIPAA and other privacy laws.
How We Collect Personal Information
We use different methods and sources to collect information from and about you, including through:
- Direct interactions. You may give us information about you by interacting with our website, communicating with us via email or contact us page, or by interacting with us over social media.
- Third party or publicly available sources. We may receive information about you from third parties, including educational institutions. For more detail, please refer to our Privacy Policy or Education Privacy Notice.
- Technical and Communication Data. When you visit our website and when we send you marketing emails, we collect certain information automatically using cookies and other technologies, such as web beacons.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- Create, register, and maintain your account with the Services.
- Manage our relationship with you, including dealing with your enquiries and support requests.
- Administer and protect our Websites and Services.
- Improve and develop our Websites, Services, and relationships with Users.
- Make suggestions and recommendations to you about our Services.
- Personalize our Services for you.
- Complete a transaction with us for Services.
- Detect, prevent, and address technical issues.
- Comply with laws.
- Allow Users to log into the Services automatically.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories
- Category F: Internet or other similar network activity
- Category I: Professional or employment-related information
- Category J: Non-public education information
- Category K: Inferences drawn from other personal information
Sale of Personal Information/Targeted Advertising
In the preceding twelve (12) months, we have not sold any personal information or shared any personal information for targeted advertising.
Using your Sensitive Personal Information
Sensitive personal information means personal information that reveals several specific details about a consumer. This information is used to process your payment for products and services.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information:
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months.
Deletion and Correction Request Rights
You have the right to request that we delete and/or correct any of your personal information that we collected from you and retained, subject to certain exceptions.
Your Right to Opt-Out of Sale or Sharing Your Information
We do not sell or disclose personal information with third parties that would be considered a “sale” under the CCPA.
Exercising Access, Data Portability, Deletion, and Correction
To exercise your rights, please submit a request to us via our website or contact us directly.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Notice of Financial Incentives
We do not offer financial incentives for providing your personal information.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at any time.
Contact Information
If you have any questions or comments about this notice, please contact us by mail at:
Impero Solutions Inc. d/b/a Ativion, 5441 S Macadam Ave #5228, Portland, OR 97239, United States
Attn: CCPA Consumer Access Request
dpo@ativion.com