Klaviyo Privacy Notice
Updated June 29, 2023
Thank you for your interest in Klaviyo! This Privacy Notice explains how information about you, that directly identifies you, or that makes you identifiable (“personal information”) is collected, used, disclosed, and otherwise processed by Klaviyo in connection with our services.
When we use the terms “Klaviyo”, “Klaviyo Group”, “we”, “us”, or “our” in this Privacy Notice, we are referring to Klaviyo, Inc. and its affiliates. When we use the term “Service,” we are referring to all of the services and product offerings that we offer as a controller, our website https://www.klaviyo.com/ or any other Klaviyo Group product or service that posts or links to this Privacy Notice.
Klaviyo as a Data Controller: For purposes of data protection laws, Klaviyo is the “data controller” (or similar term under applicable laws) and is generally responsible for and controls the processing of your personal information collected through your use of our Service. This Privacy Notice applies only to instances where Klaviyo acts as a data controller.
Klaviyo as a Data Processor: In providing our Service, our customers may collect data in our products and services, or we may collect data on their behalf, which may include personal information or data about our customers’ end users (“Customer Data”). In such instances, Klaviyo acts as a “data processor” (or similar term under applicable laws), and we have contractually committed ourselves to process Customer Data on behalf and under the instruction of the respective customer, who is the data controller. This Privacy Notice does not apply to the processing of Customer Data and we recommend you read the privacy notice of the respective customer if their processing concerns your personal information.
Table of Contents
- How We Collect Your Personal Information
- How We Use Your Personal Information
- How We Share Personal Information
- Online Advertising
- Control Over Your Information
- Privacy Rights
- Third Party Websites and Services
- Changes to Privacy Notice
- Contact Us
- Region-Specific Disclosures
- EU-US Privacy Shield And Swiss-US Privacy Shield Certifications
- EU Representative and UK Representative
1. HOW WE COLLECT YOUR PERSONAL INFORMATION
When you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from third parties.
Personal Information You Provide
We may collect the following personal information you provide in connection with our Service:
- Account Creation and Profile Information for a Klaviyo Account. We may collect personal information that you provide when you register for an account (where available). This information includes your email and password, company name, company URL, office phone number and office address. You may also add or confirm your name, company industry, tax ID, billing address, time zone and source of contact/lead.
- Contract Data. If your company enters into a contractual relationship with us, we may collect your name, job title, email address, signature (if wet signed or a copy of their autograph is used), customer name and address, and information how you heard about us.
- Payment and Transaction Information. If you sign up for one of our Services requiring payment, we collect the information provided in connection with such payment. Please note that we use third party payment processors to process payments made to us. As such, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. We will only receive the last 4 digits of the credit card number along with transaction-related information (i.e., payment date, amount, device type, IP address and card type). If custom billing is arranged, the account contact’s name, email, job title, company and address may be collected as well.
- Communications. When you contact us through any method of communications, including through one of our website “Contact Us”, “Chat” or “Support” functions or you request a demo of the Klaviyo platform, we may collect your name, email address, mailing address, phone number, company/company URL, account ID, type of inquiry, or any other personal information you choose to provide to us, such as how many contacts you have/your company has, which products interest you, what platform is currently being used, and meeting dates and times.
- Newsletter, Marketing Emails, and Blog. If you sign up to receive news or alerts from us, or subscribe to our blog, we may collect your email and applicable interests and communication preferences.
- Klaviyo Academy. If you sign up for training sessions via the Klaviyo Academy, we ask for your user’s name, email, and password. You may add a profile picture. When using the platform, a user’s history on registrations, courses taken, scores, and product certifications, survey responses and lead status as well as unique identifier are captured.
- Klaviyo Community. If you wish to participate in the Klaviyo network with other account holders and find resources, insights and further support from other used, you may participate in the Klaviyo Community. In this case we may collect the following data: your account credentials, your Klaviyo account ID, email address and partner ID. Your account will also show classifications based on your involvement in the Community and badges showing your based on your involvement/accomplishment (both of which can be manages in the profile settings to be visible or not visible to other users of the Community) as well as all content you share via the Community function. Moreover, you may add your name, username, job title, city, country, profile picture, social media (Instagram and Twitter), and bio/signature details that may be visible to the other users of the Community.
- Klaviyo Partner. If you apply to be a Klaviyo partner, we may collect personal information that you provide when you sign up (where available). This information includes your name, email, title, business phone number, company name, company URL and office address.
- Events, Surveys, Feedback and Promotions (including Contests, Sweepstakes, Webinars, and Training Sessions). If you fill out any forms or otherwise provide your information to us in connection with Klaviyo events, surveys, or other promotional events (including contests, sweepstakes, webinars, and trainings), as well as when you provide feedback to us, we may collect your contact information (such as your name, email, and phone number), your organization company, your job title, the office address and any other information you provide to us.
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers and partners collect certain personal information automatically when you visit, interact with, or use our Service:
- Log Data: Including your internet protocol (IP) address, operating system, browser details such as type, ID, and configuration, unique identifiers, device type and version, the referring URL, date/time of your visit, the time you spent on our services and any errors that may occur during your visit to our Services.
- Analytics Data: Including the electronic path you take to our services, through our services and when exiting our services, UTM source, as well as your usage and activity on our services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
- Location Data: Including your general geographic location based on the IP address we collect.
- Platform data: If you have an account to use the services we offer as a processor, we may in addition also collect your name, phone number, email address, company information, status in the sales cycle, lead and commercial details (like platform specifics, initial marketing channel), and user and account ID and other identifiers (such as Salesforce ID and Klaviyo ID), NPS/account sentiments, Klaviyo Academy user profile/history data, account health status, event attendance, status as lead/account, integrations.
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.
Personal Information from Other Sources and Third Parties
We may also obtain personal information from third parties, which we may combine with personal information we collect either automatically or directly from an individual.
We may receive personal information from the following third parties:
- Klaviyo Entities: We may receive personal information from other companies and brands owned or controlled by Klaviyo Group, and other companies owned by or under common ownership as Klaviyo Group.
- Klaviyo Business and Marketing Partners. We may also disclose personal information with other business and marketing partners with whom we jointly offer products or services, co-market or host events, or who are part of our partner ecosystem. The information we disclose may include your name, phone number, email address, company name and address, opportunity/interest details of your company, and information on whether your company is a current client of our partner.
- Social Media: When an individual interacts with us through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Facebook, Twitter, Instagram or other social networks through, for example, the social media buttons embedded into our website, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers: Our service providers that perform services solely on our behalf, such as chat services, payout processing, and marketing providers, collect personal information and often share some or all of this information with us.
2. HOW WE USE YOUR PERSONAL INFORMATION
We may use the personal information we collect for the following purposes:
- Fulfill our contractual obligations, to deliver the Services you have requested, including facilitating your messages to other users or groups and for account and contract management (including customer support);
- Communicate with individuals, including via email, text message, social media and/or telephone and video calls;
- Review our business performance;
- Market and Sales of our Services to individuals, including through email, direct mail, phone, video call, text message, or through other forms of communications platforms (i.e., WhatsApp);
- Send gifts to you;
- Administer, improve and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services and analyzing our client-base;
- Process payment for our Services;
- Conduct market research;
- Opportunity tracking, conversion and lead generation;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Enforce our Terms of Service, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- Process and deliver contest and sweepstakes entry and awards; and
- Comply with legal obligations.
3. HOW WE SHARE PERSONAL INFORMATION
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as described below.
- Service Providers: We share personal information with third party contractors and service providers, that are subject to reasonable confidentiality terms, and which may include processing payments, providing web hosting and maintenance services, technology support providers, email and messaging communications providers, analytics providers, data storage providers, and web and video hosting providers and developers. Any such service providers will be subject to confidentiality provisions, and be bound to only process the data on our behalf and under our instructions, unless such service providers act as their own controllers (e.g., in the case we seek advice from lawyers and tax consultants).
- Klaviyo Group: We may share with other companies and brands owned or controlled by Klaviyo Group, and other companies owned by or under common ownership as Klaviyo Group. These companies will use your personal information in the same way as we can under this Privacy Notice.
- Business and Marketing Partners: We may also disclose personal information with other business and marketing partners with whom we jointly offer products or services, co-market or host events, or who are part of our partner ecosystem. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own privacy notices.
- Advertising Partners: We may share certain personal information (including information collected through cookies) with our advertising service providers and vendors in order to advertise our Services to you. For more information on how we collect and share this information, please see the Online Advertising section of this Privacy Notice.
- Corporate Transaction: We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, change of control or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Notice.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud; or
- as otherwise required by applicable law.
- The Public/Other Klaviyo Community users, when you post content on the Klaviyo Community portion of the website: Remember, our websites allow you to connect and interact with others. In that case, your personal data may be visible to others as set out above under “Klaviyo Community”.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our website or service-related publications.
4. ONLINE ADVERTISING
We may share (or we may permit these parties to collect) personal information with online advertising networks, social media companies, and other third-party services, including information about your use of our Service over time, so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, clickstream information, browser type, time and date you visited the website and other information. This information is used to display targeted ads on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, Twitter, Google, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them. For more information on our online practices specifically in relation to cookies, please see our Cookie Notice.
5. CONTROL OVER YOUR INFORMATION
- Email Communications. From time to time, we may send you emails regarding updates to our Services, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices).
- Messaging Platforms. We may use personal information we collect to communicate with individuals via messaging platforms (such as WhatsApp), including to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from these messages at any time by replying STOP in one of our messages.
- SMS Text Messaging. We may use personal information we collect to communicate with individuals via text message, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For more information, please see our Terms of Service.
- Modifying Account Information. If you have a Klaviyo service account with us, you have the ability to modify certain information in your account (e.g., your contact information and profile picture) through the “Contact Information” tab in the “Account” section in your Klaviyo account. Not all personal information is maintained in a format that you can access or change. If you would like to request access to, or correction or deletion of personal information, you may send your request to us by messaging support in the support portal through your Klaviyo account. We will review your request and may require you to provide additional information to identify yourself, but we do not promise that we will be able to satisfy your request.
6. PRIVACY RIGHTS
In accordance with applicable privacy law and the jurisdiction in which you reside (including, without limitation, Colorado, Connecticut, Utah, and Virginia), you may be able to exercise some or all of the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- Right of access and portability. You may have the right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information.
- Right to correction. You may have the right to require us to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
- Right to deletion. You may have the right to request the deletion of your personal information, subject to certain exceptions.
- Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or the “sale” of your personal information to third parties in certain contexts. You may also have the right to direct us not to use automated decision-making or profiling for certain purposes.
- Right to exercise control over sensitive personal information. You may have the right to exercise control over our collection and processing of certain sensitive personal information.
- Right to non-retaliation. You may have the right to be free from retaliatory or discriminatory treatment for exercising any of the rights described above.
Before processing your request, we will need to verify your identity and confirm you are a resident of a jurisdiction that offers such right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To exercise your right to opt-out: please submit a request, as follows:
Opt-out of targeted advertising (cookies opt-out), please use our cookie management tool:
cookie management tool
Unless you have exercised your right to opt-out, we may disclose or “sell” your personal information to third parties for monetary or other valuable consideration, or use your information for all the purposes described in this Privacy Notice, including for targeted advertising. The third parties to whom we sell or disclose personal information may use such information for their own purposes in accordance with their own privacy statements.
You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
8. THIRD PARTY WEBSITES AND SERVICES
The Services may contain integrations or links to third party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party and not Klaviyo. Please note that Klaviyo is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy notices and online terms of those third parties to learn more about how they handle your personal information.
9. CHANGES TO PRIVACY NOTICE
We reserve the right to change this Privacy Notice from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by adequately informing you via your account, by placing a prominent notice on our website, or through other appropriate communication channels. It is your responsibility to review this Privacy Notice periodically. All changes shall be effective from the date of publication unless otherwise provided.
10. CONTACT US
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to email@example.com.
11. REGION-SPECIFIC DISCLOSURES
This Privacy Notice is designed to apply to our website visitors, users of our Service, and other companies and users on a global basis. Please refer below for additional disclosures that may be applicable to you:
ADDITIONAL DISCLOSURES FOR AUSTRALIA RESIDENTS
These additional disclosures for Australian residents (“Australian Disclosures”) supplement the information contained in our Privacy Notice and applies solely to individuals in Australia (“you”).
These Australian Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individuals in Australia, either online or offline, within the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”) found in Schedule 1 of the Privacy Act.
Unless otherwise expressly stated, all terms in these Australian Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the Privacy Act.
When we use the term “personal information” in this Australian Disclosures notice, we mean information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion:
- is true or not; and
- is recorded in a material form or not.
A. HOW WE COLLECT YOUR PERSONAL INFORMATION
The various ways in which your personal information is collected are described in section 1 of our Privacy Notice, We may also collect your personal information if we record any phone calls or video calls (with your permission) between you and Klaviyo.
B. OVERSEAS TRANSFERS OF YOUR PERSONAL INFORMATION
Your personal information may be transferred to and stored in locations outside Australia where we and our third-party service providers have operations, including in the United States, where Klaviyo, Inc. is located and the United Kingdom.
In the event of a transfer by Klaviyo to a location outside Australia, we ensure that: (i) personal information is transferred to countries recognised as having an equivalent level of privacy protection to Australia; or (ii) the transfer is made pursuant to appropriate safeguards, such as contractual obligations.
C. STORING YOUR PERSONAL INFORMATION
We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers.
We will never send you unsolicited emails or contact you by phone requesting credit or debit card information.
D. YOUR PRIVACY RIGHTS
You have various rights under the APPs.
Right to access and request
You have the right to request access to and/or the correction of your personal information held by Klaviyo. You can exercise these rights by contacting our Privacy Officer at firstname.lastname@example.org.
We will respond to your request within a reasonable time. If your request is refused, you will be provided with written reasons for the refusal and information about the mechanisms you can use to complain about the refusal.
Right to complain
You also have a right to make a privacy complaint to our Privacy Officer at email@example.com.
Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. Our Privacy Officer will endeavour to complete the investigation into your complaint promptly. You may be asked to provide further information about your complaint and the outcome you are seeking. Our Privacy Officer will then typically gather relevant facts, locate and review relevant documents, and speak with individuals involved.
In most cases, our Privacy Officer will investigate and provide a written response to your complaint within 30 days of receipt of the complaint. If the matter is more complex or the investigation may take longer, our Privacy Officer will let you know.
If you are not satisfied with Klaviyo’s response to your complaint, a complaint may be made to the Office of the Australian Information Commissioner (“OAIC”). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS (UNITED STATES)
These additional disclosures for California residents (“CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”).
These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”)
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
A. COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information from and about you for a variety of purposes, as described in the How We Collect Your Personal Information and How We Use Your Personal Information sections of the Privacy Notice.
Categories of Personal Information Collected. In the last 12 months, we have collected the following categories of personal information:
- Identifiers, such as your first, middle and last name, email address, username, or other similar identifiers;
- CA Customer Categories, such as your name, phone number, and postal address;
- Commercial Information, such as records of services purchased, obtained or considered;
- Internet/Network Information, such as device information, logs and analytics data;
- Geolocation Data, such as approximate location data generated based on your IP address or other information;
- Sensory Information, such as recordings of any phone calls or video calls (with your permission, as applicable) between you and Klaviyo;
- Professional/Employment Information, such as the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization, job application information and other details contained in your resume;
- Inferences about your interests and preferences, generated from your use of our sites; and
- Other Personal Information, including information you submit into the feedback form and any communications between you and Klaviyo, as well as information we receive from social networking sites.
We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit our App or use our Services, or from third parties that you permit to share information with us. Please see the How We Collect Your Personal Information section of the Privacy Notice for more information about the sources of personal information we collect.
B. DISCLOSURE OF PERSONAL INFORMATION
We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) analytics providers; (iv) marketing and strategic partners; and (v) social networks.
In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the Collection and Use of Personal Information section of these CA Disclosures, to third parties for a business purpose, as describe the How We Share Your Personal Information section of the Privacy Notice.
C. SALE OF PERSONAL INFORMATION
As further described in the How We Share Your Personal Information section of the Privacy Notice, we may “sell” or “share” your personal information (as those terms are defined by the CCPA) to third parties, subject to your right to opt out of those sales or sharing (see Exercise Your Right to Opt-Out below).
In the last 12 months, we have sold or shared the following categories of personal information for the purposes described in our Privacy Notice, subject to your settings and preferences and your Right to Opt-Out: Identifiers, such as your name and email address, CA Customer Categories, such as your name and phone number, and Commercial Information, such as records of services purchased, obtained or considered.
The categories of third parties to whom we may sell or share the personal information include:
- Business and Marketing Partners
- Online Advertising Networks and Analytics Providers
- Social Networks
We may also disclose personal information to third parties at your direction or upon your request, in connection with a corporate business transaction, or to comply with legal or contractual obligations, as described in our Privacy Notice.
D. YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):
|The Right to Access/Know|
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information;
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling the personal information.