What is the CCPA?
The California Consumer Privacy Act, or CCPA, is a new law that provides California consumers certain rights in relation to their personal information. . Generally speaking, the CCPA gives California residents the following rights:
- Right to know what personal information a business has collected about you.
- Right to tell a business not to sell your personal information.
- Right to request deletion of personal information.
For more details, check out the State of California CCPA web site.
What is a consumer?
Personal information of consumers is defined broadly and includes personal information of employees and business-to-business contact information. In addition, personal information can be obtained not only from consumers, but also households and devices.
Whom does CCPA apply to?
- Do business in the state of California;
- Collect personal information (for itself or through another party);
- Alone or jointly determines the purpose or means of processing personal information and
- Satisfies one of the following
- Annual gross revenue of $25 million,
- Alone or in combination, annually buys, receives for the business’ commercial purposes, sells, or shares for commercial purposes, alone or in combination, the personal information of 50,000 or more consumers, households or devices or
- Derives 50% or more of its annual revenues from selling consumers’ personal information
We have determined that CCPA applies to the services Webtrends performs on behalf of our clients and so we must be in a position to support compliance with the law.
Does Webtrends share or sell client data?
No. Webtrends collects data on behalf of our clients when you visit their web sites or applications. The information is only available to the client and is not aggregated, sold, or shared with any third party.
As a Webtrends client, does the CCPA apply to me?
Most likely, but this is a legal determination and we strongly recommend you speak with your legal team about its applicability to your specific business.
What about Webtrends?
Webtrends is a “service provider” (as that term is defined under CCPA) in relation to the data collected via our SaaS solutions. Clients control what data is collected and where it is collected from.
What personal data is collected and processed via Webtrends’ solutions?
CCPA defines “personal information” very broadly . Of the categories identified as personal information under CCPA, Webtrends’ SaaS solutions : (1) IP address; (2) randomly generated Globally Unique Identifier or GUID, and (3) geolocation information associated with a device. Clients control the collection of any additional personal information.
Keep in mind that combining multiple data elements, even if not considered individually considered personal information, may result in the combined data being considered personal information.
Can I avoid collecting personal data when using Webtrends’ solutions?
Given CCPA’s broad definition of personal information, it would be impossible for the Webtrends solutions to work without personal information. Webtrends does provide functionality to allow clients to truncate IP addresses. In addition, clients may contact Webtrends’ Technical Support team to discuss other options for minimizing the collection of personal data.
Are there certain types of data that cannot be collected and processed via Webtrends’ solutions?
Yes. Webtrends’ SaaS solutions are not intended for processing data that could be legally considered sensitive in any applicable jurisdiction (e.g. government-issued identification or credit card numbers). Webtrends calls this “Prohibited Data”, and the default configurations of Webtrends’ tagging methods do not collect Prohibited Data. Webtrends prohibits clients from using our solutions to collect, store, process, or analyze Prohibited Data, and does not accept liability for Prohibited Data.
When does Webtrends delete client data?
Webtrends deletes client data, including backups, within 60 days following termination of the agreement. Please refer to Webtrends’ Data Retention Policy (Exhibit B to Webtrends’ Terms of Subscription Service) for more information about data retention during the term of the agreement.
Does Webtrends provide clients with the option to delete client data?
Webtrends supports the deletion of client data; however, this must be done by Webtrends’ Technical Support team pursuant to a Statement of Work.
Does Webtrends utilize augmentation data?
Yes. Webtrends augments client data with information from third party systems to provide additional geographical and device information in reports. No information is shared with these third parties.
Where is the data held?
Webtrends leverages data collection centers in the United States, Ireland, and Germany. All data is processed and stored in the United States.
Webtrends’ Commitment to Data Protection
- Webtrends commitments under the CCPA are reflected in the Webtrends Data Protection Addendum.
- Robust Security Practices. Webtrends employs technical and organizational measures designed to prevent unauthorized access, use, alteration, or disclosure of Client Data collected via Webtrends’ SaaS solutions). Further, Webtrends has more than 15 years of experience in operating highly secure SaaS solutions with security controls that are continuously updated to meet industry standards and emerging threats. This is described in detail in Webtrends’ Security Statement.
For more information, please contact us at firstname.lastname@example.org.