Privacy Policy

Below is a simplified description of a new law on website privacy (the Online Privacy Protection Act of 2003) for anyone with a website visited by people living in California, and on which website collects info on those who visit that site.

While most of our websites don’t likely collect info directly from consumers (via cookies and such), they do suggest consumers e-mail us, and with those e-mails we do collect information. Therefore. we need to add a “privacy policy” in the main menu of each of our websites.

Who Must Comply
The new law applies to all “operators” of commercial websites and online services that collect personally identifiable information about California consumers. This includes out-of-state operators as well as those based in California.

The term “operator” means the owner of a website or an online service. It does not include third parties that may operate, host or manage the site or service or who process information on behalf of the owner. The term “personally identifiable information” means individually identifiable information collected online about individual consumers, such as a first and last name, a street address, an e-mail address, a telephone number, a social security number or any other identifier that would permit the operator, or others who obtain access to that information, to contact a specific individual. The term “consumer” means any individual who seeks or acquires goods, services, money or credit for personal, family or household purposes. OPPA does not apply to owners of websites that only collect information about other businesses.

What the New Law Requires
The new law requires an operator to conspicuously post a privacy policy on its website or in the case of an online service, to use reasonable means to make that policy available to consumers.

In order to meet the “conspicuously posted” requirement:
• The privacy policy must appear prominently on the home page of a website;
• The privacy policy must be directly linked to the home page by means of an icon that contains the word “privacy” and uses a color that contrasts with the background of the web page; or
• The privacy policy must be linked to the home page by means of a hypertext link that includes the word “privacy,” is written in capital letters equal to or greater in size than the surrounding text, or is otherwise readily distinguishable from the surrounding text on the home page.

The privacy policy itself must do all of the following:
• It must identify the categories of personally identifiable information that the operator collects;
• It must identify the categories of third parties with whom the operator may share the personally identifiable information
that it collects;
• It must describe the process (if any) by which consumers can review and request changes to any of the collected
information;
• It must describe the process by which the operator will notify consumers of material changes in its privacy policy; and
• It must identify the effective date of the privacy policy.