ClickBank Privacy Notice for California Residents

Last updated: April 25, 2023 

Related: ClickBank Privacy Policy 

This Privacy Notice for California Residents (“CA Privacy Notice”) supplements the information contained in the ClickBank Privacy Policy, which is incorporated into this CA Privacy Notice by reference.  This CA Privacy Notice applies to California residents from whom Click Sales Inc. (“ClickBank,” “we, or “us”) collect personal information (“Consumers” or “you”), including when you visit clickbank.com, clkbank.com, or clickbank.net (collectively, the “Site”).  We adopt this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020, also known as Proposition 24 (“CPRA”),and any terms defined therein have the same meaning when used in this CA Privacy Notice. 

Information We Collect 

This Site collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).  In particular, within the last 12 months, the Site has collected the following categories of Personal Information from the sources and for the business or commercial purposes described below: 

Personal information does not include: 

• Publicly available information from government records. 
• Deidentified or aggregated consumer information. 
• Information excluded from the CCPA and CPRA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”), California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”). 

In addition to the business or commercial purposes for the collection described above we have, in the preceding 12 months, collected all categories of personal information described above (“Personal Information”) for the following purposes: 

• To process your requests, purchases, payments, and transactions and to prevent transactional fraud. 
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses. 
• To create, maintain, customize, and secure your account with us. 
• To test, research, analyze, and develop products, including to develop and improve this Site,  our products, and services. 
• To provide, support, personalize, and develop this Site and our products and services. 
• To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business. 
• To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through this Site, third-party sites, and via email or text message (with your consent, where required by law). 

We will continue to collect the Personal Information from the sources and for the business or commercial purposes described above.   

We may also use or disclose the Personal Information we collect for one or more of the following purposes: 

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. 
• As described to you when collecting your personal information or as otherwise set forth in the CCPA and CPRA. 
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ClickBank’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ClickBank about the users of this Site is among the assets transferred. 

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

Disclosures of Personal Information for a Business Purpose 

We share your Personal Information for a business purpose to the following categories of third parties:  

• Service providers 
• Clients 

When we disclose your Personal Information to a service provider, we enter into a contract with them that describes the business purpose for which your Personal Information is disclosed and which restricts their use of your Personal Information for any purpose except those performed under the contract. 

In the preceding 12 months, we have disclosed to these third parties the following categories of Personal Information for a business purpose:  

• Customer Records Data 
• Commercial Data. 
• Internet Use Data. 
• Location Data. 

In the preceding 12 months, we have not sold Personal Information. 

Your Rights and Choices 

The CCPA and CPRA provide you, as California residents, with specific rights regarding your Personal Information.  This section describes your CCPA / CPRA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you: 

• The categories of Personal Information we collected about you. 
• The categories of sources for the Personal Information we collected about you. 
• Our business or commercial purpose for collecting or selling that Personal Information. 
• The categories of third parties with whom we share that Personal Information. 
• The specific pieces of Personal Information we collected about you (also called a data portability request). 
• If we disclosed for a business purpose or sold your Personal Information, two separate lists relating to: 
• Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 
• Sales, identifying the Personal Information categories that each category of recipient purchased. 

Deletion Rights 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records and their records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service providers in order to: 

• Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
• Debug products to identify and repair errors that impair existing intended functionality. 
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law. 
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
• Comply with a legal obligation. 
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it. 

Exercising Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an email to privacy@clickbank.com. 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request in order to confirm the Personal Information relates to you. 

Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable, in light of the nature of the Personal Information requested.   

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights. 

Response Timing and Format 

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time, we will inform you of the reason and extension period in writing, up to a maximum of 90 days. 

If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by regular mail or email, at your option.  

Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.  Alternatively, we may decline to respond to the request and notify you of our reason for doing so. 

Personal Information Sales and Sharing Opt-Out and Opt-In Rights 

We do not sell or share, and we have not in the 12 months preceding the date of this Privacy Notice sold or shared, any personal information, as “sell” and “share” are each defined by the CCPA. If we do start selling or sharing personal information, we will notify you in writing and either get your express written consent or provide you with the opportunity to opt out of such sale and/or sharing.  

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA / CPRA rights.  Unless permitted by the CCPA or CPRA, we will not: 

• Deny you goods or services. 
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties. 
• Provide you a different level or quality of goods or services, including denial of goods or services. 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

However, we may offer you certain financial incentives permitted by the CCPA / CPRA that can result in different prices, rates, levels, or quality of goods or services.  Any CCPA / CPRA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

Other California Privacy Rights 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of this Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an email to privacy@clickbank.com  or write us at: 1444 S. Entertainment Ave., Boise, ID 83709. 

Changes to this Privacy Notice 

ClickBank reserves the right to update or change this CA Privacy Notice at any time.  When we make changes to this CA Privacy Notice, we will post the updated notice on this Site and update the date on which this CA Privacy Notice was last updated.  The date this CA Privacy Notice was last updated is at the top of this page.  You are responsible for periodically reviewing this Site and this CA Privacy Notice to check for any updates or changes.  Your continued use of this Site following the posting of changes constitutes your acceptance of all such changes. 

Contact Us 

If you have any questions or comments about this CA Privacy Notice or our privacy practices, your choices and rights regarding use of your Personal Information, or wish to exercise your rights under California law, please contact us at: 

Email: privacy@clickbank.com

Postal Address:  

ClickBank 
1444 S. Entertainment Ave., Suite 410 
Boise, ID 83709