Supplemental Privacy Notice for California Residents

Effective May 8th, 2021

This Supplemental Privacy Notice for California Residents supplements the information
contained in the Foolproof Living (“we” or “us” or “our”) Privacy Policy and applies solely
to all visitors, users, and others who reside in the State of California (“consumers” or
“you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018
(CCPA) and any terms defined in the CCPA have the same meaning when used in this

Information We Collect

Our Site collects information that identifies, relates to, describes, references, is capable
of being associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or device (”Personal Information”). In particular, we have collected
(or not collected, if indicated below) the following categories of personal information
from its consumers within the last twelve (12) months:

A. Identifiers.A real name, postal address, unique personal
identifier, online identifier, Internet Protocol
address, email address, account name, or
other similar identifiers.
B. Personal information
categories listed in the
California Customer Records
statute (Cal. Civ. Code §
A name, signature, address, telephone
number, education, employment, employment
history, credit card number, debit card
number, or any other methods of payment for
our products, or medical information.
Some personal information included in this
category may overlap with other categories.
C. Protected classification
characteristics under
California or federal law.
Age (40 years or older), medical condition,
physical or mental disability, sex (including
gender, gender identity, gender expression,
pregnancy or childbirth and related medical
conditions), veteran or military status. These
categories are ONLY collected in very limited
circumstances where the consumer voluntarily
and knowingly provided the information.
D. Commercial information.Records of products or services purchased,
obtained, or considered.
E. Biometric information.Genetic, physiological, behavioral, and
biological characteristics, or activity patterns
used to extract a template or other identifier or identifying information, such as, fingerprints,
face prints, and voiceprints, iris or retina
scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data.
F. Internet or other similar
network activity.
Browsing history, search history, information
on a consumer’s interaction with a website,
application, or advertisement.
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO

We obtain the categories of personal information listed above from the following
categories of sources:

  • Direct interactions. You may give us your information by filling in forms or by corresponding with us by email. This includes, but may not be limited to, personal data you provide when you:
    • Subscribe to our publications;
    • Interact with our website such as commenting on posts, downloading recipes, subscribing to our newsletter, or acquiring e-publications;
    • Interact with social media by visiting our social network accounts, commenting on, or liking posts;
    • Enter a giveaway
    • Complete a survey; or
    • Provide information by email or through our contact form.
  • Automated technologies or interactions. As you interact with our Site, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical data from the following parties:
      • Analytics providers such as Google;
      • Website newsletter providers such as Mailerlite;
      • Data from publicly available sources such as internet search engines based inside and outside the United States.

Use Of Personal Information

We may use and/or disclose the personal information we collect for one or more of the
following business purposes:

  • To register you as a new subscriber
  • To manage our relationship with you which may include, but are not limited to:
    • (a) Notifying you about changes to our terms or privacy policy
    • (b) Asking you to leave a review or take a survey
  • To delivery products your purchase on the Site
  • To enable you to participate in a giveaway
  • To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)
  • To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To use data analytics to improve our Site, products/services, marketing, customer relationships, and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you

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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we require that the
recipient both keep that personal information confidential and not use it for any purpose
except performing the contract.

We disclose your personal information for a business purpose with the following
categories of third parties:

  • Entities owned in whole or in part by Foolproof Living and/or its owners.
  • Professional advisers including lawyers, bankers, auditors and insurers who
    provide professional services.
  • Regulators and other authorities who require reporting of processing activities in
    certain circumstance.
  • Service providers
  • Other individuals, services, and partners at your request
  • Contest and promotions partners
  • Advertisers, ad networks and advertising partners
  • Social media networks
  • Entities for legal purposes

Sales of Personal Information

In the preceding twelve (12) months, We have not sold any categories of personal
information (for both minors and non-minors). We do not sell personal information to
third parties. While we do not sell your information to any third party in the traditional
sense of the word ‘sell’, the definition of ‘sell’ provided in the CCPA is much more broad
so we are providing notice that we may partner with third-party service providers and
affiliate partners who may gain access to your personal information through the use of
beacons, tracking pixels, or cookies.

California Information & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about
your personal information. Specifically, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information, the business or commercial purpose for collecting your personal information, and the categories of third parties with whom we share/disclose personal information;
  • Provide access to and/or a copy of certain personal information we hold about you;
  • Delete certain personal information we have about you; and
  • Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Site to you.

Verification: We will take reasonable steps to verify your identity before responding to a
request, which may include, at a minimum, depending on the sensitivity of the
information you are requesting and the type of request you are making, verifying your
name, e-mail address, and physical address.

You are also permitted to designate an authorized agent to submit certain requests on
your behalf. In order for an authorized agent to be verified, you must provide the
authorized agent with signed, written permission to make such requests or a power of
attorney. We may also follow up with you to verify your identity before processing the
authorized agent’s request.

Deletion Request Right

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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or
our service provider(s) to:

  • Complete the transaction for which we collected the personal information, 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 their 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.).
  • 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 that 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 at


Only you, or a person registered with the California Secretary of State that you
authorize 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 and confirm the personal
information relates to you.

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

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of
its receipt. If we require more time (up to 90 days), we will inform you of the reason and
extension period in writing. We will deliver our written response electronically using the
email address you provide in your request.

Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request’s receipt. 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 it 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.


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

  • Deny you goods or services.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive different goods or services or a different level or quality of goods or services.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect
or use your information described in this Supplemental Privacy Notice for California
Residents, your choices and rights regarding such use, or wish to exercise your rights
under California law, please do not hesitate to contact us at: