1. Overview

This California Consumer Privacy Act (CCPA) policy describes the privacy rights of California residents under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020, collectively "CCPA") when using the LocalReach Rewards platform. This policy supplements our Privacy Policy and applies only to California residents.

2. We Do Not Compile or Sell Your Data

We do not compile customer data beyond what is already described in our Privacy Policy. We do not aggregate, enrich, or combine your personal information with data from third-party data brokers or external sources to build expanded profiles. The only personal information we collect, use, and store is what you voluntarily provide when creating an account, participating in campaigns, and using the platform — as described in Section 1 of our Privacy Policy.

We do not sell personal information. Under the CCPA, "sale" includes sharing data for monetary or other valuable consideration. We have never sold, rented, or bartered personal information to any third party, and we do not share your information with third parties for cross-context behavioral advertising. No opt-out is necessary because there is nothing to opt out of.

3. Categories of Personal Information We Collect

Consistent with our Privacy Policy, we collect the following categories of personal information as defined by the CCPA:

Identifiers — email address, display name, account ID.
Commercial information — campaign records, payout history, transaction records (payment processing handled by Stripe).
Internet or electronic network activity — IP address, approximate geolocation (city, state, country), device type, browser, pages visited, tracking link and QR code activations.
Professional or employment information — business name, industry, creator bio, social media handles (provided voluntarily).
Inferences — engagement scores and fraud risk indicators derived from the above.

We do not collect the following categories under the CCPA: Social Security numbers, driver's license numbers, financial account numbers, precise geolocation, biometric information, health information, or racial or ethnic origin.

4. How We Use Your Information

We use the personal information described above only for the business and commercial purposes listed in our Privacy Policy, including:

Providing, operating, and improving the LocalReach Rewards platform
Calculating creator engagement scores from verified local data
Processing payouts and verifying payment eligibility
Detecting and preventing fraud and platform abuse
Maintaining audit trails for compliance with SOC 2 and ISO 27001 controls
Sending transactional notifications about your account and campaigns
Responding to support requests and enforcing our Terms of Service

We do not use your personal information for any purpose that is materially different from the purposes disclosed at the time of collection.

5. Your California Privacy Rights

As a California resident, you have the following rights under the CCPA:

Right to know — Request that we disclose the categories and specific pieces of personal information we have collected about you, the sources, the business purpose, and the categories of third parties with whom we shared it.
Right to delete — Request that we delete personal information we have collected from you (subject to legal retention obligations such as audit logs and financial records).
Right to correct — Request that we correct inaccurate personal information we maintain about you.
Right to opt-out of sale or sharing — We do not sell or share your personal information, so no opt-out action is required. No "Do Not Sell or Share My Personal Information" link is needed.
Right to limit use of sensitive personal information — We do not collect sensitive personal information as defined by the CCPA, so this right is not applicable.
Right to non-discrimination — We will not discriminate against you for exercising any of your CCPA rights. We will not deny service, charge different prices, or provide a different level of service based on your exercise of these rights.

6. How to Exercise Your Rights

To exercise any of your California privacy rights, submit a request by emailing privacy@localreachrewards.com with the subject line "CCPA Request." Please include:

Your full name and email address associated with your account
The specific right you wish to exercise (know, delete, or correct)
A description of the information you are requesting or want corrected or deleted

We will verify your identity before processing your request. We respond to all verified requests within 45 days. If we need more time, we will inform you in writing within the first 45 days and may take up to an additional 45 days.

You may also designate an authorized agent to submit a request on your behalf by providing written authorization. We may still require you to verify your identity directly with us.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in our Privacy Policy, including legal, accounting, and audit requirements. Account data is deleted within 30 days of a verified deletion request. Tracking events are retained for the campaign lifetime plus 3 years. Audit logs and payment records are retained for 7 years as required by applicable law.

8. Minors

Our platform is not directed to individuals under 16, and we do not knowingly collect personal information from children under 16 without parental consent. If you believe we have collected information from a minor, please contact us at privacy@localreachrewards.com and we will promptly delete it.

9. Changes to This Policy

We may update this CCPA policy to reflect changes in the law or our practices. We will notify California users of material changes via email or a prominent notice on our website at least 14 days before they take effect.

10. Contact Us

For California privacy questions or to submit a CCPA request:
Email: privacy@localreachrewards.com
Postal: LocalReach Rewards, [Address], Fort Worth, TX

California Consumer Privacy Act (CCPA) Policy