Supplemental Privacy Statement

Last Updated: January 6, 2024

This supplements the information contained in the https://www.lotuswebservicesinc.info/privacy-policy and applies solely to visitors, users and others who reside in the State of California (“Consumers” or “You”). We adopt this notice in this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2023 (“CPRA”) and any terms defined in the CCPA and/or CPRA have the same meaning when used in this section.

What information do we collect within the last 12 months?

We may have collected and disclosed, for a business purpose, information from the following categories in the last twelve months:

Business contact information of clients, prospects, partners and suppliers
Information necessary to respond to your request for information, order or support
Information necessary to provide you with access to and use of our websites, products and services
Information collected for marketing and business intelligence
Information about visitors to our sites and locations
(for job applicants submitting electronic information) your educational background, employment experience, and job interest;
any other identifier that permits Tungsten Automation to make physical or online contact with you;
any information that we collect online from you and maintain in association with your account, such as your username and your password;
any other information that you provide to us when using our web shop or when you are communicating with us.

this includes Personal Information defined by the CCPA as:

The following is a list of all categories of Personal Information specified in Section 1798.140(o) of the CCPA that Tungsten Automation has collected from California residents in the twelve (12) months prior to the Effective Date, together with (1) examples of the types of Personal Information we collect within that category, and (2) the categories of sources from which we collect such Personal Information:

Identifiers (1) examples of what we collect: name, username/password, email address, office and/or home address, office and/or personal phone numbers, ethnicity, and other similar identifiers; (2) sources: you, third parties including public sources, service providers, publications, commercial clients.
Commercial information (1) examples of what we collect: records of your purchases of our services, prescribing history and claims data; (2) sources: you, third parties including service providers, commercial clients.
Online Identifiers: (1) examples of what we collect: cookies, device identifiers, IP addresses; (2) sources: you.
Internet or Network Information: (1) examples of what we collect: browsing history, search history, and information about your interaction with our websites, applications and advertisements (collectively, “Interaction Data”); (2) sources: you.
Geolocation Data: (1) examples of what we collect: city, state, and zip code; (2) sources: you (directly and indirectly from your IP address)
Personal information under the Customer Records provision of the California Civil Code (1) examples of a name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. (Some personal information included in this category may overlap with other categories.) (2) sources: you, third parties including service providers, commercial clients
Professional Employment Information: (1) examples of what we collect: current and past employment; (2) sources: you and third parties including business partners, service providers, commercial clients, employers, public sources, publications.
Physical Description: (1) examples of what we collect: physical description apparent from a photo; (2) sources: you, employers, public sources, business partners.
Inferences (1) examples of what we collect: inferred preferences and interests; (2) sources: automatically generated internally based on other information we collect about your use of the Service as described in this notice.
Communications: (1) examples of what we collect: contents of faxes and messages exchanged through the Service; (2) sources: you and other users of the Service

Personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s and/or CPRA’s scope, including without limitation: 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) or clinical trial data.
Personal information is covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

How we use your Personal Information

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

To fulfill or meet the reason You provided the information.
To provide, support, personalize, and develop our Site and Services.
To create, maintain, customize, and secure Your account with Us.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our responses.
To personalize Your experience and to deliver content and product and service offerings relevant to Your interests, including offers and ads through Our Site, third-party sites, and via email (with Your consent, where required by law).
To help maintain the safety, security, and integrity of Our Site, Services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve Our Site and Services.
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/or CPRA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about Our users 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

Who will we share your data with?

We may collect Personal Information directly from you, automatically from your device, from selected partners and/or from your employer. We may share information about you with our subsidiaries, suppliers and, where appropriate, with selected partners to help us provide you, or the company you work for, products or services, or to fulfill your requests, or with your consent.

Sale of Personal Information

When you use Tungsten Automation websites, Tungsten Automation’s authorized partners may collect cookies and similar technologies and use this data for their own purposes. This activity may qualify as a “sale” under the CCPA. Depending on your choices, during the past twelve months, we may have “sold” information within the following categories defined by the CCPA:

Identifiers like IP address and cookies (limited to a numeric identifier, such as an IP address)
Internet activity information relating to your interactions with Tungsten Automation websites
Inferences about your consumer preferences
Commercial Information
Internet or Similar Network Activity
Geolocation Data and Inferences drawn from other Personal Information

Privacy Rights

Under the California Consumer Privacy Act (CCPA), California residents have certain rights related to their personal information collected by and on behalf of a business subject to the law. In addition to the rights granted under the https://www.lotuswebservicesinc.info/privacy-policy, as a California resident, you have the right to:

Right to know your personal Information

California residents may request a business to disclose the following information about the business’ collection and use of their personal information over the past twelve (12) months, provided that such requests are made no more than twice within a twelve (12) month period:

The categories of personal information collected;
The categories of sources for the personal information collected;
The business or commercial purpose for collecting, and, if applicable, selling, personal information;
The specific pieces of personal information collected;
If the personal information has been disclosed, the categories of personal information disclosed and the categories of third parties receiving the personal information;
If the personal information has been sold, the categories of personal information sold and the categories of third parties to whom the personal information was sold.

You can request specific pieces of Personal Information, or information about the categories of Personal Information that Tungsten Automation holds about you by submitting a request through ou https://www.lotuswebservicesinc.info/contact-us or by calling (toll free) +1-855-789-2922

Right to Access Specific Information and Data Portability Right

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 twelve (12) months. Once We receive and confirm Your verifiable consumer request, 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 Your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.
If applicable, (1) the categories of personal information We have sold; (2) the categories of personal information that We sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.

Right of Deletion

California residents may request a business to delete the personal information that the business collected and has been retained by the business or its service providers. This right is limited, and the business may deny a deletion request if it is necessary for the business or a service provider to maintain the personal information in order to:

Complete the transaction for which the personal information was collected, provide a good or service requested by the individual, or reasonably anticipated within the context of a business’ ongoing business relationship with the individual, or otherwise perform a contract between the business and the individual.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, where the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the individual has provided informed consent;
Enable solely internal uses that are reasonably aligned with the expectations of the individual based on the individual’s relationship with the business;
Comply with a legal obligation;
Otherwise use the individual’s personal information, internally, in a lawful manner that is compatible with the purpose for which the individual provided the information.

Right of No Sale or Share of Personal Information

A California resident has the right to opt-out of the sale of their Personal Information by a business subject to the CCPA. In addition, a business subject to the CCPA must have affirmative authorization in order to sell the Personal Information of a California resident who it knows is under the age of 16.

You can submit a request through our https://www.lotuswebservicesinc.info/contact-us or by calling (toll free) +1-888-245-5360

Right of Limit the Use of My Sensitive Personal Information

A California resident has the right to opt-out of the sale of their Personal Information by a business subject to the CPRA.

The CPRA defines sensitive personal information as personal information that reveals:

Social Security number, driver’s license, state identification card, or passport number;
Account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
Precise geolocation;
Racial or ethnic origin, religious or philosophical beliefs, or union membership;
Mail, email, and text message content, unless the business is the intended recipient of the communication;
Genetic data;
Biometric information processed for the purpose of identifying a consumer;
Personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation;

Sensitive personal information under the CPRA doesn’t include any publicly and lawfully available information through federal, state, or local records.

Right of Non-Discrimination

A business subject to the CCPA may not discriminate against a California resident for exercising any of their CCPA privacy rights.

We will not discriminate against You for exercising any of Your CCPA and/or CPRA rights. Unless permitted by the CCPA and/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;.
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 and/or CPRA that can result in different prices, rates, or quality levels. Any CCPA and/or 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.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by either:

Calling us at +1-888-245-5360
Submitting a request through https://www.lotuswebservicesinc.info/contact-us
Do Not Sell or Share My Personal Information
Limit the Use of My Sensitive Personal Information

Only You, or a person registered with the California Secretary of State that You authorise 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 such a request for access or data portability twice within a 12-month period.

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.

Response times 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 45 additional days), we will inform you of the reason and extension period in writing. 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 electronically. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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.

Please note that we may deny your deletion request if retaining your information is necessary for us or our service providers 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.).
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 that information that are compatible with the context in which you provided it.

How to Contact Us

If you have any questions about this Policy or about Tungsten Automation’s handling of your personal information, you may submit a request through our https://www.lotuswebservicesinc.info/contact-us or by calling (toll free) +1-855-789-2922

To read more about Tungsten Automation's general privacy practices that apply to the Personal Information we collect, use and share, please visit the https://www.lotuswebservicesinc.info/privacy-policy

01/16/2024