Privacy Policy - US Baseline (California)

[COMPANY NAME] CALIFORNIA PRIVACY NOTICE

Effective Date: [__/__/____]

Last Updated: [__/__/____]

This Privacy Notice explains how [COMPANY LEGAL NAME] ("Company," "we," "us," or "our") collects, uses, retains, sells, shares, and otherwise discloses personal information through [LIST COVERED WEBSITES, APPLICATIONS, PRODUCTS, SERVICES, AND OFFLINE INTERACTIONS] (collectively, the "Services").

1. SCOPE AND CONTACT DETAILS

Company address: [________________________________]

Privacy email: [________________________________]

Toll-free number: [________________________________]

Request form: [________________________________]

Privacy choices link: [________________________________]

This Notice applies to: [DESCRIBE COVERED CALIFORNIA CONSUMERS AND INTERACTIONS].

This Notice does not apply to: [IDENTIFY PROCESSING COVERED BY A SEPARATE NOTICE OR STATUTORY EXEMPTION].

2. PERSONAL INFORMATION WE COLLECT

For the 12 months preceding the Last Updated date:

We may create aggregated or deidentified information. We maintain deidentified information in that form and do not attempt to reidentify it except as permitted by law.

3. HOW WE USE PERSONAL INFORMATION

We use personal information, as applicable, to:

• provide, maintain, personalize, and improve the Services;
• create and administer accounts and transactions;
• communicate about services, support, security, and offers;
• conduct analytics, research, advertising, and campaign measurement;
• authenticate users and detect fraud, abuse, and security incidents;
• comply with law and legal process and protect rights and safety; and
• evaluate or complete a corporate transaction.

We do not collect additional categories or use collected personal information for materially different purposes without providing the notice or obtaining the consent required by law.

4. PRIOR 12-MONTH DISCLOSURE PRACTICES

Recipient categories may include hosting and security providers, payment processors, analytics providers, advertising and social-media partners, customer-support and fulfillment providers, professional advisers, affiliates, governmental authorities, litigants, and corporate transaction recipients.

5. NOTICE AT COLLECTION

At or before each point of collection, make a readily available notice that identifies:

• the categories of personal information and sensitive personal information collected;
• the purposes for which each category is collected or used;
• whether each category is sold or shared;
• the retention period for each category, or the criteria used to determine it; and
• links to this Notice and the required sale, sharing, or sensitive-information choice method.

Notice-at-collection locations: [________________________________]

6. SALE, SHARING, AND PRIVACY CHOICES

☐ We do not sell personal information or share it for cross-context behavioral advertising.

☐ We sell or share the categories identified in Section 4.

California consumers may opt out through:

• Do Not Sell or Share My Personal Information: [LINK]
• privacy request form: [LINK]
• other permitted method: [________________________________]

Where required, we process an opt-out preference signal, such as Global Privacy Control, as a request to opt out for the browser or device that sends the signal. We will explain any account-level option and will not require a consumer to use a verification process for a sale or sharing opt-out beyond what the regulations permit.

We do not knowingly sell or share the personal information of consumers under 16 without the affirmative authorization required by law. [CUSTOMIZE AGE-ASSURANCE AND OPT-IN PROCESS OR REMOVE IF INAPPLICABLE.]

7. SENSITIVE PERSONAL INFORMATION

We collect and use the following sensitive personal information: [________________________________].

We use it for: [________________________________].

☐ We use or disclose sensitive personal information only for purposes that do not trigger the CCPA limitation right.

☐ We use or disclose sensitive personal information in a manner that requires a right to limit. Consumers may submit a request through [LIMIT THE USE OF MY SENSITIVE PERSONAL INFORMATION LINK OR OTHER METHOD].

8. COOKIES AND OTHER TRACKING TECHNOLOGIES

Browser Do Not Track response: [________________________________]

Whether other parties collect activity over time and across different websites or services: [________________________________]

9. CALIFORNIA PRIVACY RIGHTS

Subject to coverage, verification, and statutory exceptions, a California consumer may have the right to:

• know the categories and specific pieces of personal information collected;
• obtain information about sources, purposes, sales, sharing, business-purpose disclosures, and recipient categories;
• access and obtain a portable copy of personal information;
• correct inaccurate personal information;
• delete personal information;
• opt out of sale or sharing;
• limit certain uses and disclosures of sensitive personal information; and
• receive equal service and not be unlawfully discriminated against for exercising a CCPA right.

California law does not create the controller-denial appeal process found in some other state privacy laws.

Submit a Request

• Web form: [________________________________]
• Toll-free number: [________________________________]
• Email or other method, if used: [________________________________]

We will respond within the period required by law. We may verify a request and may deny or limit it where a statutory exception applies.

Authorized Agents

An authorized agent may submit a covered request on a consumer's behalf. We may request proof of authorization and may ask the consumer to verify identity or confirm the authorization directly, subject to applicable law.

10. FINANCIAL INCENTIVES

☐ We do not offer a program that requires a notice of financial incentive.

☐ We offer this program: [PROGRAM NAME AND MATERIAL TERMS]. The program involves [PERSONAL INFORMATION], and the good-faith value calculation, opt-in process, and withdrawal method are: [________________________________].

11. AUTOMATED DECISIONMAKING TECHNOLOGY

California's regulations effective January 1, 2026 establish January 1, 2027 as the compliance date for their automated-decisionmaking-technology requirements. Do not describe those access or opt-out procedures as legally available before that date unless the Company has implemented them voluntarily.

Systems and decisions in scope after counsel review: [________________________________]

January 1, 2027 notice, access, and opt-out implementation: [________________________________]

12. CHILDREN'S PRIVACY

☐ The Services are general audience, are not directed to children under 13, and we do not knowingly collect personal information online from a child under 13.

☐ The Services are child-directed or we have actual knowledge of collection from a child under 13. Our children's notice is at [LINK], and we provide notice and obtain verifiable parental consent as required by the Children's Online Privacy Protection Act and 16 C.F.R. Part 312 unless an exception applies.

13. RETENTION, SECURITY, AND INTERNATIONAL PROCESSING

We retain each category of personal information only for the period reasonably necessary and proportionate to its disclosed purpose, subject to legal, accounting, security, fraud-prevention, and dispute-resolution needs.

We maintain administrative, technical, and physical safeguards designed to protect personal information. No security measure is guaranteed to prevent every incident.

Personal information may be processed in [COUNTRIES OR REGIONS]. Where a transfer mechanism or additional safeguard is legally required, we use [DESCRIBE MECHANISM].

14. CHANGES AND CONTACT

The "Last Updated" date identifies the latest version. We will provide additional notice and obtain consent before a material change when required.

Questions, requests, or complaints may be sent to:

[COMPANY LEGAL NAME]

Attn: [PRIVACY TEAM OR OFFICER]

[ADDRESS]

[EMAIL]

[PHONE]

SOURCES AND REFERENCES

• 15 U.S.C. § 45
• 15 U.S.C. § 6502
• 16 C.F.R. Part 312
• California Consumer Privacy Act
• California Online Privacy Protection Act
• CCPA statute and regulations effective January 1, 2026

Conform this notice to the Company's data inventory, request operations, vendor contracts, advertising technologies, retention schedule, and coverage analysis before publication.