Who We Are
California Do Not Track Disclosure
Currently, 6200 Productions does not respond to Do Not Track browser settings.
Information-Sharing Disclosures (Shine the Light Law)
California Civil Code § 1798.83 et seq. (the “Shine the Light” law) gives California residents who have established business relationships with certain businesses the right to request information about those businesses’ disclosure of the customer’s personal information to third parties for direct marketing purposes.
The law defines “direct marketing purposes” as “the use of personal information to solicit or induce a purchase, rental, lease, or exchange of products, goods, property, or services directly to individuals by means of the mail, telephone, or electronic mail for their personal, family, or household purposes.” An “established business relationship” is defined as “a relationship formed by a voluntary, two-way communication between a business and a customer” that is either ongoing or was established with a purchase or other transaction within the past 18 months.
Under the Shine the Light law, if you are a California resident and have an established business relationship with a business subject to the law’s requirements, you may request, once per calendar year, an Information-Sharing Disclosure that details:
- What categories of personal information about you, if any, that business shared with third parties for direct marketing purposes in the preceding calendar year, and
- The names/identities and addresses of such third parties.
(The law does not require the business to reveal which specific pieces of information may have been shared, only the categories of information, as defined by the applicable statutes.)
Although we believe we are exempt from the requirements of this law, since we have fewer than 20 employees, we will nonetheless make every reasonable effort to provide you with such a disclosure within 30 days of our receipt of your request. To submit a request, please contact us via any of the methods described in “Controllers/Responsible Parties, Questions, and How to Reach Us” below.
Additional California Privacy Rights (CCPA)
Starting January 1, 2020, California privacy laws, including the California Consumer Privacy Act of 2018 (CCPA), give California residents additional rights with respect to their personal information. The rights the CCPA provides California residents include:
- The Right to Know (sometimes described as the right to access): You have the right to request — free of charge, and (where possible) in “a readily usable format”:
- The categories and/or specific pieces of personal information we have collected about you in the preceding 12 months, and
- The categories of business and/or commercial purposes for collecting and using that information, and
- The categories of sources from which we collected that information, and
- The categories of personal information about you that we have shared with third parties for business or commercial purposes in the preceding 12 months, and
- The categories of third parties with whom personal information was shared.
- The Right to Delete: You have the right to request deletion of personal information about you that we have collected in the course of our business.
- The Right to Opt-Out of the sale of your personal information.
- The right to not receive discriminatory treatment for exercising these rights.
- The right to make a complaint to a state government supervisory authority.
- The right to take private legal action in the event of a data breach that exposes your personal information to theft or unauthorized access.
These rights are subject to certain exemptions, exceptions, and restrictions provided by the law and/or its associated regulations. You need not be physically present in California to exercise these rights provided that you have a current California residence. You may designate an authorized agent to act on your behalf in exercising these rights.
While we believe 6200 Productions does not technically meet any of the applicability thresholds specified by this California law, we are committed to providing visitors with as many privacy choices as we reasonably can.
You (or your authorized agent) can exercise your California privacy rights via any of the methods specified on the Do Not Sell My Personal Information page.
Applicable law and/or regulations stipulate the maximum time allowed for acknowledging and/or responding to your request. There is no charge for for making a request.
In order to better safeguard your privacy and the privacy of others, we may be required to verify your identity before processing certain requests pertaining to your personal information. We may be unable to fulfill your request if we cannot verify your identity to the degree of certainty applicable law and/or regulations require. (You can find more information in the “Identity Verification Requirements” section of the Do Not Sell My Personal Information page.) The CCPA regulations issued by California’s Office of the Attorney General stipulate that if we request additional personal information from you that we did not already possess in order to verify your identity to the degree of certainty those regulations require, we may use such additional personal information solely for that purpose and may only retain that information to the extent necessary to comply with the regulations’ record-keeping requirements.
Even if we verify your identity, the regulations prohibit us from disclosing certain types of extremely sensitive personal information (e.g., Social Security Numbers or financial account numbers) in response to a request to know. (In the event that we possessed such sensitive personal information about you, the regulations would only permit us to disclose the fact that we possessed the information, not tell you the actual information we possessed.)
Please note that in addition to any exceptions and exemptions applicable law and/or regulations may provide to the rights provided by the CCPA (particularly with regard to the deletion of your personal information), we may be unable to delete certain information (e.g., our web host’s server and error logs) for technical reasons.
Except as otherwise required by law, privacy-related requests pertaining to children under 18 should be submitted by a parent, legal guardian, or other authorized adult representative.
Opting-Out or Submitting Other California Privacy Requests (Do Not Sell My Personal Information Page)
If you are a California resident and would like to exercise your Right to Opt-Out of the sale of your personal information, or any of your other rights under the California Consumer Privacy Act of 2018 (CCPA), such as the Right to Know (a.k.a. the right to access) and/or the Right to Delete your personal information, you (or your authorized agent) should visit our Do Not Sell My Personal Information page.
CCPA Information Collection and Sharing Notice
The California Consumer Privacy Act of 2018 (CCPA) also requires certain businesses to provide California residents with additional information about the categories of personal information the business collects, the sources from which the business gets that personal information, and how and why the business uses and/or shares that personal information. These disclosures must be updated at least once a year.
As noted above, we believe we do not meet any of the CCPA applicability thresholds, but for the avoidance of doubt, we make the disclosures listed below.
Categories of Personal Information Collected
Please note that we do not necessarily collect all of these categories of personal information about every individual, or even most individuals. While we collect certain information from all site visitors (e.g., IP addresses, user agent information), the categories listed below also encompass the range of information we gather in connection with the articles and other content we create and/or edit (and/or on which we consult and/or otherwise collaborate) and/or our other creative endeavors, which is far more extensive than we customarily gather about site visitors. (Simply reading a single magazine article or encyclopedia entry about some public figure as part of our research can sometimes provide us with most if not all of the categories of personal information listed here!) These categories also include information (a) that certain people volunteer to us, whether about themselves or someone else; (b) that we only collect from/about certain people for some specific reason(s); and/or (c) that we infer or surmise from other data (e.g., inferring an approximate geographical location based on an area code or email domain).
The statutory definitions of some of these categories overlap, with certain types of information (e.g., real names) technically falling into multiple categories; we have tried to limit repetition in the interests of space and comprehensibility. This list also includes some types of information that the law would probably regard as personal information, but that are not specifically described in the applicable statutes and/or regulations.
The examples listed for each category are intended to be a representative sampling, NOT an exhaustive list of all the specific pieces of information we may gather and/or have gathered within a particular category. Also, this list describes the categories of information we collect and/or have collected about individuals and/or households from ANY locale, NOT only from California residents. (In many cases, we have no reasonable way to know whether the individuals and/or households to whom certain personal information pertains are California residents or not.)
In the last 12 months, we have collected the following categories of personal information in the course of our business:
- Identifiers, such as:
- Real names, pseudonyms/aliases, nicknames, usernames, and/or account names
- IP addresses
- Email addresses
- Postal mailing addresses and/or street addresses
- Social Security Numbers, taxpayer ID numbers, driver’s license numbers, and/or other government-issued identification numbers
- Unique personal identifiers, device identifiers, online identifiers, and/or other similar identifiers
- Information collected through cookies and/or similar technologies
- Additional categories of personal information as defined in the California Customer Records statute, California Civil Code § 1798.80(e), such as:
- Signatures, physical and/or digital
- Other physical characteristics and/or descriptions of individuals (e.g., height, weight, hair color, distinguishing marks and/or distinguishing features)
- Telephone numbers (and/or FAX numbers)
- Other contact information
- Account numbers
- Records of financial transactions with and/or otherwise involving us, including, where applicable, but without limitation, transaction ID numbers, tax-related information, billing addresses, full and/or partial credit card information, check information, bank account and/or other financial institution account information, and/or other account details (we do NOT receive any credit card, bank account, or other financial institution account information in connection with PayPal® transactions; PayPal is a registered trademark of PayPal, Inc.)
- Other financial information (e.g., credit ratings; whether someone has (or had) loans, past foreclosures, and/or declared bankruptcy; other information pertaining to creditworthiness, assets, benefits, income, and/or liabilities; the net worth of public figures)
- Medical information (e.g., information about health conditions; tests and/or treatments received; drugs, therapies, and/or medical products and/or equipment used; healthcare providers and/or organizations visited, consulted, and/or otherwise used or seen)
- Health insurance information (e.g., whether or not individuals or households are insured and if so, with which insurance provider(s) — we do NOT collect policy numbers or similar data, and much of what health-insurance-related data we do collect is in aggregated form)
- Information about other types of insurance and/or insurance coverage
- Characteristics of classifications protected by law, such as:
- Age and/or date of birth
- Race, color, ancestry, national origin, citizenship, and/or residency
- Religion and/or creed
- Marital/relationship status and/or information about spouses/partners
- Medical condition and/or physical or mental disability
- Sex, gender, gender identity, and/or gender expression
- Pregnancy, childbirth, and/or related medical conditions
- Sexual orientation
- Veteran or military status
- Information about children (such as the number of children and/or their names, ages, and/or genders) and/or other family members
- Language(s) spoken and/or preferred
- Commercial information, such as:
- Information about cars and/or other vehicles an individual or household has owned, purchased, rented, leased, otherwise obtained, and/or considered; that they have indicated they want to purchase, rent, lease, and/or otherwise obtain; and/or that they are considering
- Information about art, books, other publications, films and/or other videos, music, and/or other media an individual or household has read, watched, viewed, listened to, and/or otherwise consumed; desires/intends to read, watch, view, listen to, and/or otherwise consume; and/or is considering reading, watching, viewing, listening to, and/or otherwise consuming
- Information about personal property, products, goods, and/or services an individual or household owns, rents, leases, has otherwise obtained, and/or uses; has owned, purchased, rented, leased, otherwise obtained, used, and/or considered; desires to purchase, rent, lease, otherwise obtain, and/or use; and/or is considering purchasing, renting, leasing, otherwise obtaining, and/or using
- Information about food, beverages, groceries, meals, recipes, drinks, and/or cuisine(s) an individual or household purchases, otherwise receives and/or obtains, prepares, consumes, prefers, and/or disdains
- Information about retailers, vendors, marketplaces, and/or service providers an individual or household has patronized, is considering patronizing and/or planning to patronize, prefers, and/or disdains
- Information about lodgings, residence(s), office space(s), and/or other real property an individual or household owns, rents, leases, and/or otherwise uses (and/or is considering purchasing, renting, leasing, and/or otherwise using), and/or information about who owns, manages, administers, sells, rents, leases, and/or otherwise offers for commercial advantage particular lodgings; a particular residence; and/or a particular building, lot, office space, industrial facility, or other real property
- Information about stock and/or securities ownership, purchases, sales, and/or transfers (e.g., whether an individual or household owns and/or has recently purchased and/or sold shares in a particular corporation or other business entity, and/or what broker(s) and/or other intermediaries, if any, conducted and/or administered such transaction(s))
- Information about other types of purchases, transactions, and/or investments
- Information about an individual or household’s participation and/or interest in sports, games, hobbies, and/or other pastimes
- Information about an individual or household’s participation, scores, achievements, winnings, losses, and/or prizes in sweepstakes, lotteries, raffles, contests, wagers, other forms of gambling, and/or other games of chance or skill
- Information about an individual or household’s critical judgments, tastes, opinions, and/or preferences
- Other information about an individual or household’s purchasing and/or consuming history and/or tendencies
- Information about products, goods, services, and/or property an individual or household sells, rents, leases, and/or otherwise offers for commercial advantage
- Biometric information, such as if you provide us with information about your health, sleep, and/or exercise habits, and/or if we configure our smartphone(s) and/or other device(s) to be unlocked using a fingerprint
- Internet or similar network activity information, such as:
- Web browsing activity and/or history
- Search history
- Information gathered through cookies and/or similar technologies
- User agent information
- Email header information
- Online avatars, profile images, and/or icons
- Domain names and/or URLs of personal blogs, social media pages/feeds, and/or other online profiles
- Network, shared device, and/or online service information (e.g., names, passwords/login credentials, URLs, IP addresses, technical details, and/or other information pertaining to wireless networks; local area networks; shared printers and/or other devices; databases; websites; online accounts; and/or other means of networking, connecting, sharing, and/or otherwise accessing electronic devices, files, messages, communications, and/or data)
- Other information about an individual or household’s use of and/or interactions with websites, applications, software, devices, electronic systems and/or services (online and/or otherwise), messages, and/or advertisements, including, but not limited to, information about errors and/or suspicious activity
- Geolocation data, such as an individual or household’s physical location and/or movements, whether directly observed; stated and/or described to us (directly or indirectly); and/or determined, estimated, and/or inferred from other data (e.g., from an IP address, telephone area code, and/or GPS coordinates)
- Sensory data (audio, electronic, visual, thermal, olfactory, or similar information), such as photographs, illustrations and/or other images, films and/or other videos, audio recordings, broadcasts, live streams, voice and/or video calls or chats, and/or other media in which recognizable individuals and/or their identifiable likenesses are visible and/or their voice(s) audible
- Professional or employment-related information, such as:
- Current and/or past employer(s) and/or client(s)
- Job title(s) and/or position(s)
- Work schedule(s), location(s), and/or assignment(s)
- Compensation and/or benefits
- Business or organization ownership, officership, and/or registration information (e.g., whether an individual has some ownership interest in and/or is an officer of a corporation, some other business entity, or a nonprofit organization)
- Information about professional clients, clientele, customers, users, advertisers, vendors, suppliers, contractors, subcontractors, and/or service providers
- Information about other professional relationships (such as, without limitation, publishing and/or licensing deals, management, representation, endorsement deals, contractor and/or subcontractor relationships, colleagues, coworkers, mentor/mentee relationships, professional collaborations, joint ventures, and/or partnerships)
- Military service information
- Membership in and/or affiliation with other organizations and/or groups
- Professional certification(s) and/or license(s)
- Training, professional development, career goals, and/or professional aspirations
- Skills, aptitudes, abilities, and/or intelligence
- Professional achievements and/or honors
- Publishing histories/bibliographies/discographies/filmographies/performance histories/broadcast histories/portfolios/development credits/patent records and/or other, similar and/or comparable information about writers, artists, photographers, designers, architects, filmmakers, musicians, performers, translators, editors, producers, developers, researchers, scientists, engineers, inventors, and/or other such professionals
- Authorship, other credits, and/or rights holder information for creative works, designs, inventions, and/or performances (e.g., books, articles, scientific and/or engineering studies, essays, blog posts, photographs, illustrations and/or other images, films and/or other videos, songs and/or musical compositions, choreography, audio recordings, films, television and/or radio programs, other media, software, architectural plans, mechanical inventions and/or blueprints, designs of whatever type, and/or other types of artwork and/or creative endeavors), and/or other types of intellectual property such as trademarks, service marks, and/or patents
- Professional references
- Performance evaluations and/or information about an individual’s professional reputation and/or conduct
- Other information about an individual’s current, past, and/or prospective work, vocation, trade, professional services, products, and/or other commercial endeavors
- Nonpublic education information, such as school applications and/or attendance; class lists; grades and/or test scores; transcripts; major(s); degree(s), certifications, and/or credentials earned and/or in progress; graduation date(s); other information about a current or former student’s instructors, coursework, academic projects, and/or academic performance; and/or information about student loans and/or financial aid
- Inferences we draw from other personal information, such as our estimation of an individual’s personality, aptitudes, predispositions, psychological trends, and/or behavior
- Other types of personal information not specifically described in the applicable statutes, such as:
- Information about specific vehicles, such as license plate numbers, vehicle identification numbers, related information (e.g., vehicle registration dates); vehicle position(s) and/or location(s); and/or other identifying characteristics or details (e.g., year, make, model, body style, color, equipment, features, distinguishing markings, modifications, customization, damage, repairs, and/or maintenance)
- Information about individuals’ places of birth and/or upbringing
- Information about an individual or household’s involvement in and/or connection with accident(s), natural disaster(s), and/or other catastrophic event(s) or hardship(s) (of whatever type(s) and/or cause(s))
- Legal information (e.g., information regarding an individual having been accused of, charged with, and/or convicted of crime(s), infraction(s), and/or misconduct; having been a victim (or alleged victim) of crime(s) and/or misconduct; and/or being involved in a civil lawsuit)
- Information about an individual or household’s employees, independent contractors, interns, agents or other authorized representatives, and/or service providers (e.g., assistant and/or secretary, attorney(s) and/or other legal counsel, talent and/or literary agent(s), manager(s), broker(s), accountant(s), auditor(s), and/or other authorized representatives and/or professional service providers)
- Information about wills, estates, executorship, inheritance, trusts, trusteeship, conservatorship, and/or guardianship
- Information about gifts, donations, charitable contributions, and/or political contributions made and/or received
- Information about community service (e.g., jury duty), volunteer work, and/or charitable activity
- Information about political affiliations, opinions, and/or activity
- Information about other beliefs, opinions, feelings, predispositions, attitudes, and/or viewpoints
- Information about social class, rank, position, title, and/or investiture, of whatever type(s) and/or source(s)
- Information about membership in and/or affiliation with clubs, societies, fraternal orders, and/or other types of groups
- Information about awards, honors, prizes, and/or other recognition
- Information about individuals’ public and/or personal reputations
- Information about friendships, personal relationships, and/or social interactions (including observations and/or inferences regarding individuals’ tendencies and/or preferences therein)
- Information about other household members (e.g., roommates) and/or pets
- Information about an individual’s style(s), themes, influences, tendencies, development, and/or achievements in writing, art (in whatever medium(s)), photography, filmmaking, music, fashion, design, architecture, and/or other creative endeavors (professional or otherwise)
- Handwritten notes and/or documents; illustrations; paintings; sketches; and/or other examples of individuals’ handwriting, calligraphy, and/or artwork (in whatever medium)
- Encryption public keys and/or similar security data
- Other potentially personally identifying information in electronic files and/or associated metadata
- Other types of personal information, and/or other types of data that could potentially be deemed personal information, that do not readily fit into any of the above-listed categories.
Although we do not knowingly collect personal information from children under 18 through this website, we may sometimes collect such information as part of our professional writing/editing/writing consulting work. (For example (but without limitation), we might write or edit a news article about a minor child’s notable achievements or involvement in some matter of public interest, which could include personal information obtained through an interview with that child and/or from other sources.) If you have questions, if you are a parent or legal guardian and believe that we may have collected personal information about your minor child, or if you wish to exercise your right to remove or delete such information, please contact us via any of the methods described in “Controllers/Responsible Parties, Questions, and How to Reach Us” below. (Parents or legal guardians can also submit CCPA requests on behalf of their minor children via any of the methods specified on the Do Not Sell My Personal Information page.)
The fact that we collected and/or inferred certain information does not necessarily mean that we still retain it, or that we have any practical way to associate the different categories of information we may have collected about a given individual or household (e.g., to connect a visitor’s name with an IP address in the server logs and/or a face visible in the background of a photograph).
Personal information we collect about you and/or your household comes from one or more of the following categories of sources, whether directly or indirectly:
- You, whether through your interactions with us; through public disclosures you make (e.g., social media posts); through your use of this website; and/or through your employees, independent contractors, interns, agents or other authorized representatives, business partners, vendors, and/or service providers (as applicable)
- Our employees, independent contractors, interns, agents, and/or business partners, if any (and as applicable)
- Our vendors and/or service providers
- Other visitors/users
- Published and/or publicly available sources (e.g., news reports, books, articles, reports and/or white papers, films and/or other videos, television programs, radio programs, podcasts, other audio recordings, social media, websites, online databases and/or repositories, public records)
- Nonpublic documents, records, collections, and/or archives (e.g., unpublished correspondence, manuscripts, and/or interviews; unreleased versions, outtakes, scripts, and/or other materials from film, television, radio, and/or other media projects; internal business and/or organizational records, reports, memoranda, documents, and/or other materials; school transcripts and/or other school records)
- Subject matter experts, other writers, historians, biographers, researchers, instructors and/or coaches, academics, scientists and/or engineers, journalists, critics, reviewers, enthusiasts, collectors, librarians and/or other library staff, archivists, translators, photographers, videographers, filmmakers, illustrators, podcasters, other media creators, publicists and/or promoters, public relations representatives and/or other press contacts, observers, eyewitnesses, and/or other knowledgeable parties (which in some cases may include (without limitation) personal and/or professional acquaintances (whether yours, ours, and/or someone else’s), such as (again without limitation) friends, current and/or past employers and/or supervisors, current and/or past colleagues and/or coworkers, current and/or past clients and/or customers, current and/or past business partners, professional references, current and/or past instructors and/or students, and/or other members of a given household and/or family)
- Clients or employers for whom we provide (or have provided) writing/editing/writing consulting services, and/or publishers and/or other third parties through which we publish, perform, broadcast, exhibit, and/or otherwise distribute our content and/or other creative endeavors (professional or otherwise).
Each of the above-listed categories of sources may provide us with information that falls into several or all of the categories of personal information listed in “Categories of Personal Information Collected” above.
- Functionality: We use the information so that this website, or certain specific functions thereof, can work properly. For example (but without limitation), none of the pages or content on this website will load if the web server doesn’t have a valid IP address to which to transmit the necessary data.
- Providing services: We use the information to perform some action you have asked us to perform; respond to comments, inquiries, and/or other messages; provide services; and/or otherwise conduct the normal activities involved in running our business and/or offering our services. For example (but without limitation), we probably couldn’t send you a physical document without your mailing or delivery address.
- Completing a transaction: We use the information to conduct or complete financial transactions, such as (without limitation) payments for our professional services.
- Fulfilling a contractual obligation: We use the information to meet the requirements of a contract or legal agreement, whether with you or with a third party.
- Legal compliance or audit: We use the information to ensure our compliance with applicable laws and/or regulations, and/or so that we can demonstrate our compliance to an auditor or investigator if needed.
- Research and publishing: We use the information in researching, creating, and/or publishing (and/or performing, broadcasting, exhibiting, and/or otherwise disseminating, as applicable) our content, our other writing/editing/writing consulting work, and/or our other creative endeavors, and/or to help us decide what content and/or other work to create and/or publish (and/or perform, broadcast, exhibit, and/or otherwise disseminate) in the future.
- Security, troubleshooting, quality control, and service improvement: We use the information to help us protect this website, its users/visitors, our data, our system(s) and/or device(s), our business, us, and/or others from malicious activity; safeguard our property, rights, security, and/or safety, and/or the property, rights, security, and/or safety of others and/or of the public at large; troubleshoot and/or resolve technical problems; and/or maintain and/or improve the quality and/or functionality of the site and/or our services.
- Recruitment/hiring/employment or business partnerships: We use the information in recruiting/hiring employees, independent contractors, and/or interns; in entering or considering entering business partnerships or other professional relationships with someone; and/or in making other types of employment decisions and/or business decisions regarding professional relationships.
- Advertising and other commercial purposes: We use the information to help us promote, pitch, and/or advertise our content, services, and/or other creative endeavors; sell advertising on this website; otherwise monetize the site, our content, our other writing/editing/writing consulting work, and/or our other creative endeavors; and/or achieve some other commercial purpose(s).
In many cases, information we collect may have several purposes or possible purposes. Obviously, not every individual piece of information in a particular category will necessarily be used or even useful for a given purpose.
Information Shared for Business or Commercial Purposes
The CCPA defines sharing information “for business purposes” as disclosing personal information about individuals or households to third parties such as service providers or independent contractors for certain specified purposes, which the law divides into the following categories:
- Auditing interactions with consumers
- Certain short-term uses
- Performing services
- Internal research for tech development
- Quality and safety maintenance and verification.
A disclosure of personal information is considered to be “for commercial purposes” if it serves to “advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction,” with the exception of “engaging in speech that state or federal courts have recognized as noncommercial speech, including political speech and journalism.”
The CCPA definitions are so expansive that almost any disclosure of virtually any piece of information about any individual or household — even information that was already publicly available — could potentially be considered sharing of personal information for business or commercial purposes if it takes place in any business-related context. Furthermore, by the CCPA definitions, a disclosure for commercial purposes may be deemed “selling” personal information even if it does not constitute a sale as most people understand that term.
Therefore, by the law’s definitions, we may share any or all of the categories of personal information we collect in the course of our business with any or all of the following:
- Our employees, independent contractors, interns, agents, and/or business partners, if any; and/or:
- Our vendors and/or service providers; and/or:
- Any government agency, investigator, auditor, court, arbiter, or other official entity that legally requires or compels us to disclose personal information related to our business; and/or:
- Any individual or entity with whom we communicate and/or consult in the course of researching, creating, and/or editing our content, writing/editing/writing consulting work, and/or other creative endeavors, and/or who communicates and/or consults with us in the course of researching, creating, and/or editing their content, work, and/or creative endeavors; and/or:
- Editors, publishers, clients, employers, and/or other third parties for whom we provide (and/or to whom we offer) our writing/editing/writing consulting services; to whom we may license, sell, and/or otherwise offer our content and/or other creative work; for whom we may otherwise work, provide services, and/or offer to work and/or provide services; with whom we may collaborate and/or offer to collaborate in performing and/or offering our services and/or in researching, creating, editing, performing, and/or offering our content, other creative work, and/or other creative endeavors; and/or as we may reasonably elect and/or be requested or directed to do as part of and/or in connection with such services, content, creative endeavor(s), collaboration(s), and/or work (and/or the offer thereof); and/or:
- Individuals and/or entities who help us promote, monetize, sell, and/or otherwise offer for commercial advantage our content, writing/editing/writing consulting services, and/or other creative endeavors; and/or:
- The public, through the publication, performance, broadcast, exhibition, other dissemination, and/or public discussion of our content and/or other creative endeavors, content we write and/or edit for others, and/or content and/or other creative endeavors on which we consult and/or otherwise collaborate (and/or public discussion of the process of researching, creating, and/or editing such content and/or creative endeavors); our sharing, discussing, and/or otherwise disseminating information that otherwise is or was already publicly available (e.g., in news reports, published works, and/or public records); our disposal of our personal property (e.g., lending, donating, or selling our copies of books, magazines, and/or other published works); and/or, as applicable, our publication of your comments, any images and/or other media you submit to us for publication and/or for use in or with work(s) intended for publication and/or other public dissemination, and/or your other communications with us.
- If that information otherwise is or was already publicly available (which is also noted in the list above, but bears repeating for emphasis — we strenuously reject and regard as unconstitutional any attempt to use the CCPA, its associated regulations, and/or similar privacy laws to restrict or limit our right to share, discuss, and/or otherwise disseminate publicly available information, whether or not that information is offered through official government sources); and/or:
- If the information is contained in and/or otherwise incorporated into artwork, a copy of a published work, a useful article, or some other object (including, without limitation, information inscribed or imprinted upon and/or affixed or otherwise attached to such work, copy, article, or object, particularly where that information cannot reasonably be removed without damage and/or defacement); and/or:
- To appropriately credit someone for the use of their images, other media, fonts, themes/plugins, and/or other content or intellectual property, particularly where such credit is required by the applicable license terms; and/or:
- As we deem reasonable and appropriate (and to the extent permitted by applicable law/regulations) to enable us to make informed hiring, employment, and/or other business decisions regarding current and/or prospective employees, independent contractors, interns, business partners, business proposals, and/or business ventures; and/or:
- If we are required by law to do so (which would typically be pursuant to a subpoena, search warrant, or other court order or administrative order; in connection with tax returns or other legally required filings, reports, registrations, or disclosures; and/or in connection with an audit, civil or criminal trial, or other official investigation or proceeding, but could also be in other circumstances that we cannot reasonably anticipate; we may also disclose certain information if we deem it reasonably necessary to ensure our compliance with applicable law or regulation, even if the specific disclosure is not expressly required, such as (without limitation) if we need to contact a tax agency to determine the correct sales/use tax rate for a particular address); and/or:
- If we are contractually obligated to do so pursuant to our agreement(s) with our business partner(s), client(s), licensor(s), licensee(s), vendor(s), and/or service provider(s) (as applicable), such as (without limitation) in connection with a dispute, an investigation, an audit, and/or arbitration; and/or:
- If we believe in good faith that such disclosure is reasonably necessary to protect property, rights, security, and/or safety, and/or to forward copyright or other intellectual property rights claims pertaining to material provided to us by a third party to that third party (since such claims may implicate their rights); and/or:
- If the person(s) to whom the information pertains (and/or, where applicable, their respective heirs, successors, and/or assigns) have asked or authorized us to do so, either directly or through their respective agent(s) or other authorized representative(s); and/or:
- If the information is de-identified, anonymized, redacted, and/or aggregated such that it could not reasonably be used to identify specific person(s) (other than us, if we are somehow included in that information and elect not to de-identify, anonymize, redact, and/or aggregate our own information); and/or:
- As part of a business transfer (e.g., if we sell or transfer control of the 6200 Productions website, our professional writing/editing/writing consulting business, and/or their respective assets; enter bankruptcy; or pass our assets to our heirs, successors, and/or assigns through our death or incapacity).
For what we hope are obvious reasons, it is not feasible for us to enumerate every possible entity or even category of entities to whom we might disclose personal information in the above contexts, but any such disclosures could also involve any or all of the categories of personal information we collect in the course of our business.
Much if not all of the personal information we collect or access in the course of our business may be processed by one or more third parties. For example (but without limitation):
- For obvious reasons, it is impossible for us to call, text, email, or mail any individual or household without disclosing a certain amount of the recipient’s personal information to third parties. For example, making a phone call or sending a text message requires communicating the recipient’s telephone number to the applicable telephone companies and/or mobile carriers.
- Our web host, DreamHost®, owns the web servers on which this website runs as well as the mail servers for our associated email addresses. Therefore, DreamHost has full administrative access to most files, messages, and data processed by or stored on those servers. This is in addition to any information we deliberately share with DreamHost for purposes such as troubleshooting or security. (DreamHost is a registered trademark of DreamHost, LLC.)
- If in the course of our business we access any website or online resource that is not encrypted, any data we access on that site or resource is visible to our Internet service provider and potentially also other third parties. Even if a website or online resource IS encrypted, our Internet service provider and other third parties (such as our DNS (domain name system) resolver service and/or the website or resource’s certificate authority and embedded content providers) can generally see that we have connected to that site or resource, as can that site/resource’s certificate authority and embedded content providers, if any. If we use a proxy server or VPN, the VPN or proxy server can also see our connections and any unencrypted data we access.
- Most payments we receive are processed by our bank(s) and/or other financial institution(s) and the applicable payment processor(s), if any. Those payments and related tax documents must also be disclosed to several different tax agencies, and may be discussed with our tax preparer(s) and/or other financial and/or legal professionals for administrative and/or compliance purposes.
Any or all of the above would likely be considered sharing information for business purposes by the CCPA definitions.
Actions like the following could also be deemed sharing information “for business purposes” if we do so in some business-related context:
- Looking up someone’s name in a search engine, library catalog, or other database.
- Entering someone’s address into a mapping or navigation service to look up driving directions, or meeting with someone face-to-face while our phone’s geolocation services are turned on.
- Using an automated translation service to translate text containing any names and/or other types of personal information.
- Printing a document containing names and/or other types of personal information using a commercial print service or a printer controlled by a third party (e.g., printing a copy of a news article we read at the public library).
- Performing a WHOIS lookup on an IP address, or allowing our firewalls and/or other security applications, software, and/or services to perform such lookups.
- Storing or transmitting any electronic file containing personal information using any cloud storage service or other online storage system.
(These are just a few examples, not an exhaustive list.)
Furthermore, because the owner of this website is a professional writer/editor and writing consultant and much (though not all) of the information we collect in connection with our business is intended for publication (and/or public performance, exhibition, and/or broadcast, as applicable), a variety of activities we routinely undertake in connection with our work could potentially be deemed “commercial” as defined by the CCPA, even if our actual content is deemed “noncommercial speech.” (For writers, photographers, and other creative professionals, the distinction between “commercial” activity and engaging in “noncommercial speech” as an integral part of one’s business is a complicated, muddy legal question mark.) Some representative examples could include:
- Licensing, selling, and/or otherwise offering offering our content or writing/editing/writing consulting services for money or other valuable consideration (potentially including publishing content on this website, which may be supported by advertising, and which we use to advertise and/or otherwise promote our work and/or professional services) if that content or those services incorporate or involve any names and/or other types of personal information about individuals or households.
- Advertising, promoting, and/or marketing our content, or published works incorporating our content, if that content contains any names and/or other types of personal information, and/or if such information is referenced in the promotion or marketing.
- Proposing or pitching any article, book, and/or other content containing names and/or other types of personal information to editors, literary agents, and/or publishers.
- Presenting and/or discussing examples of our content and/or our past or current writing/editing/writing consulting services in the course of proposing, pitching, and/or otherwise offering in a professional capacity and/or for commercial advantage our content and/or professional services (e.g., submitting some of our content as writing samples and/or describing some of our previous work as part of our application or pitch for a job or freelance assignment), if such examples incorporate or involve any personal information.
- Sharing, exchanging, or discussing with clients, coauthors, and/or collaborators any personal information pertaining to articles, books, and/or other content we are creating and/or editing (and/or on which we are consulting) in a professional capacity.
- Arranging for people featured and/or quoted in our content to receive complimentary copies of our published work or be notified of its publication or commercial availability.
Even if disclosures like these are NOT deemed to be “for commercial purposes” (or “sales”) by the CCPA definitions, they are certainly for business purposes, whether the CCPA would define them as such or not. (In certain cases, such disclosures might reasonably be regarded as part of our acting as a business service provider for someone else, particularly where the personal information involved is supplied mainly by the client rather than by us (e.g., in a manuscript we’ve been hired to edit). However, under the CCPA, being a “service provider” requires a written agreement that directs the service provider to collect and/or process personal information on the client or customer’s behalf for certain specific business purposes while restricting the service provider’s further use of that information; it’s possible to provide professional services, even to other businesses, without necessarily being considered a “service provider” as the CCPA and its associated regulations define that term.)
From time to time, we may also facilitate other types of commercial transactions, whether directly or indirectly, such as:
- By putting into contact (with their mutual consent) parties who have expressed interest in some transaction with one another. For example, if a visitor asks about licensing a photo or other content we have used that is owned by someone else, we might ask the applicable rights holder if they’re comfortable with our putting them in touch with the interested party.
- By recommending that a professional contact or acquaintance be hired for a job, assignment, or commission, or chosen as a vendor or service provider.
- By endorsing (explicitly or by implication) some author, artist, service provider, or vendor, and/or their products and/or services.
By the CCPA definitions, disclosing any personal information in such circumstances might be deemed sharing information “for commercial purposes” whether or not any transaction is actually completed, whether or not we are a party to that transaction, and whether or not we receive any compensation or other valuable consideration in connection with it.
Put simply, by the law’s extremely broad definitions, any or all of the categories of personal information we collect in the course of our business could be deemed to be shared for business and/or commercial purposes, whether or not we “sell” personal information in the way most people understand that term.
If you have general questions about our data-sharing practices (i.e., questions about our typical practices rather than about the personal information of any specific individual or household), feel free to contact us via any of the methods described in “Controllers/Responsible Parties, Questions, and How to Reach Us” below. If you are a California resident and would like to exercise your rights under the CCPA, such as the Right to Know (a.k.a. the right to access), the Right to Delete your personal information, and/or the Right to Opt-Out of the sale of your personal information, you (or your authorized agent) should visit our Do Not Sell My Personal Information page.
CCPA Request Metrics (Record-Keeping Disclosures)
- The number of requests to know that the business received, complied with in whole or in part, and denied;
- The number of requests to delete that the business received, complied with in whole or in part, and denied;
- The number of requests to opt-out that the business received, complied with in whole or in part, and denied; and
- The median or mean number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out.
Although the total number of consumers whose personal information we collect (much less purchase and/or “sell” as the CCPA defines those terms) in a calendar year doesn’t even APPROACH 10,000,000 by any remotely reasonable interpretation of the CCPA definitions, we make the following voluntary disclosures, which, for the avoidance of doubt, include all requests we received, whether through the Ate Up With Motor website, through the owner’s 6200 Productions professional writing website, through the owner’s aaronseverson.com personal website, or by any other means. (Ate Up With Motor is a trademark of Aaron Severson dba Ate Up With Motor.)
Section 999.317(h) of the regulations draws — and requires businesses to draw in making these disclosures — a distinction between requests received from consumers (which we presume means California consumers as defined by the CCPA, although the regulations are not entirely clear on this point) and requests received from all individuals. For the avoidance of doubt, the following disclosures present the total number of requests we received from all individuals during each specified period. (These disclosures DO NOT include request forms we submitted for our internal testing and/or troubleshooting purposes that were not actual requests!)
CCPA Request Metrics for the 2020 Calendar Year
|Type||Requests Received||Complied With (In Whole or in Part)||Denied||Mean Response Time||Median Response Time|
|Requests to know||1 (one)||1 (one)||0 (zero)||17.0 days||17.0 days|
|Requests to delete||8 (eight)*||6 (six)||2 (two)||8.5 days||3.5 days|
|Requests to opt-out||8 (eight)*||8 (eight)||0 (zero)||1.0 days||1.0 days|
* Totals include several duplicate deletion requests and opt-out requests.
Record-Keeping Disclosure Methodology
The CCPA regulations leave some ambiguity about what should be considered the date of “substantive response” to requests that require identity verification, a process which may take some time to complete and may require additional action on the part of the requestor. For purposes of these disclosures, our calculations reflect the date we either complied with (in whole or in part) or denied a given request.
For 2020, if we initially denied a request because we were unable to verify the requestor’s identity to the degree of certainty the regulations require, but subsequently verified the requestor’s identity to a degree of certainty sufficient to enable us to comply with the request (whether we did so or not), the disclosures reflect the final decision — and the final decision date — rather than the initial denial. We may revise this methodology for subsequent years depending on our subsequent experience.
Under California law, an opt-out request must remain in force until the consumer opts-in, so we respond to duplicate or repeated opt-out requests from a requestor who has already opted-out by affirming that the requestor’s original opt-out remains in effect. We treated all such duplicated or repeated opt-out requests as “complied with” for purposes of these disclosures.
Where we substantively responded to a request on the same day it was received, we treated the response time as 1.0 days for purposes of calculating the mean and median response times.
If you have any questions about these disclosures, feel free to contact us via any of the methods described in “Controllers/Responsible Parties, Questions, and How to Reach Us” below.
Controllers/Responsible Parties, Questions, and How to Reach Us
If you are a California resident and would like to exercise your rights under the California Consumer Privacy Act of 2018 (CCPA), such as the Right to Know (a.k.a. the right to access), the Right to Delete your personal information, and/or the Right to Opt-Out of the sale of your personal information, you (or your authorized agent) can submit a request via any of the methods specified on the Do Not Sell My Personal Information page. (To reduce the risk of confusion or error, please do not use the regular Contact Form for CCPA requests!)