California’s privacy legislation, the California Consumer Privacy Act of 2018 (CCPA), took effect this year on January 1, 2020. The CCPA bolsters consumer control over their privacy and grants California residents certain rights, amongst them a right to access/know, a right to delete, and a right to op-out, with respect to the collection, use, and sharing of their Personal Information. At Gravy Analytics, Inc. (“Gravy”), we value consumers’ privacy, and, as such, have been actively working to comply with CCPA.

Below, please find a summary of the main steps we have taken thus far to ensure that our data remains compliant with industry and legal requirements, including the CCPA.

As a data aggregator, Gravy does not have direct contact with consumers whose data is being collected. Instead, Gravy receives such data from multiple third-party sources (“Data Suppliers”) and aggregates that data to provide its products and services to its customers.  We have strengthened our contracts with our Data Suppliers by requiring our Data Suppliers not only to comply with applicable data protection and data privacy laws, including the CCPA, but also expressly requiring that they provide consumers with appropriate notices and opt-out mechanisms, and inform Gravy of opted out devices so that we may remove them from our databases and products we deliver to our customers. Gravy also maintains audit rights with its Data Suppliers which allows Gravy to verify such Data Supplier’s compliance with their contractual representations to Gravy and with applicable laws.

The CCPA increases California residents’ rights of access to and control over their personal information. Gravy is extending information access to and opt-out capabilities for consumers in all 50 US states. Gravy has added an “Opt-Out & Do Not Sell” link to our website, allowing consumers to opt-out of Gravy’s sale of their mobile advertising ID (MAID) and any associated information. Gravy will also delete from our platform, databases, systems, and products and services we deliver to our customers all information associated with an opted-out MAID. Gravy has also established an email address (privacy@gravyanalytics.com) and toll-free number (1-855-545-5623) that consumers may call to exercise their rights under the CCPA.

Gravy’s privacy policy has also been updated to comply with the CCPA. Among other changes, the policy now includes a full description of the data we receive from Data Suppliers and our use of such data, as well as supplementary information for California consumers.

Gravy is committed to responsible data collection and use practices and recently joined the National Advertising Initiative (NAI) and the Location Policy Alliance of the MMA demonstrating our compliance with industry self-regulations.

As additional guidelines about the CCPA are released by the California Attorney General, we at Gravy will continue to strengthen our privacy controls and evolve our business practices in concert with local privacy laws. Collectively, our CCPA compliance efforts provide consumers with additional control over their data and underscore our commitment to providing our clients and partners with the highest-quality location intelligence available.

If you have additional questions about the CCPA and data compliance, please contact your Gravy account representative.

Sincerely,

The Gravy Analytics Team