The purpose of this page is to explain:
(1) what it means to “sell” personal information, as those terms are defined under
Nevada law,
(2) that TKKP, LLC does not sell personal information that directly identifies you,
even under the Nevada definition of a “sale,”
(3) what happens if you tell us not to “sell” your personal information,
(4) how we implement your choice to block us from “selling” your personal
information, and
(5) how we maintain your “Do Not Sell” choice.
Why does TKKP, LLC provide the “Do Not Sell” link?
We provide the “Do Not Sell” link to comply with the Nevada Consumer Privacy Act
(NPICICA), The NPICICA is a data protection law that provides Nevada residents with
certain choices about their data, including the ability to tell companies not to “sell” their
personal information. Although the NPICICA only gives Nevada residents the right to
make these requests, we allow non-Nevada residents to make the same choices about
their personal information. See Privacy Policy.
What does it mean to “sell” personal information under the NPICICA?
Under the NPICICA, personal information includes information that identifies, relates to,
describes, is capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or household. Personal information includes, but is
not limited to, the following if it identifies, relates to, describes, is reasonably capable of
being associated with, or could be reasonably linked, directly or indirectly, with a
particular consumer or household:
Identifiers such as a real name, alias, postal address, unique personal identifier,
online identifier, internet protocol address, email address, account name, social
security number, driver’s license number, passport number, or other similar
identifiers.
Any information that identifies, relates to, describes, or is capable of being
associated with, a particular individual, including, but not limited to, his or her
name, signature, social security number, 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. “Personal information” does not include publicly available
information that is lawfully made available to the general public from federal,
state, or local government records.[ Annotation]
Characteristics of protected classifications under Nevada or federal law.
Commercial information, including records of personal property, products or
services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies.
Biometric information.
Internet or other electronic network activity information, including, but not limited
to, browsing history, search history, and information regarding a consumer’s
interaction with an internet website, application, or advertisement.
Geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Education information, defined as information that is not publicly available
personally identifiable information as defined in the Family Educational Rights
and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
Inferences drawn from any of the information identified in this subdivision to
create a profile about a consumer reflecting the consumer’s preferences,
characteristics, psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
Personal information does not include publicly available information. For purposes of
this paragraph, “publicly available” means information that is lawfully made available
from federal, state, or local government records. “Publicly available” does not mean
biometric information collected by a business about a consumer without the consumer’s
knowledge.
Personal information does not include consumer information that is deidentified or
aggregate consumer information.
The term “sell” is defined to include not just selling in exchange for money but also
sharing or transferring personal information (including information that does not directly
identify an individual as described above) in exchange for anything for value, which is
not limited to the exchange of money. Certain things are not considered “sales,”
including when (1) personal information is shared with a service provider that is
contractually prohibited from using the personal information for any purpose beyond the
service specifically requested (“service provider exception”), or (2) when the consumer
has directed a company to disclose the personal information (“consumer directed
exception”).
Does TKKP, LLC “sell” my personal information?
We do not sell information that directly identifies you, like your name, address, social
security number, or banking information. In fact, we do not even share that type of
information except with service providers who can use the information solely to provide
a service on our behalf, when a consumer directs us to share the information, or in the
limited additional circumstances outlined in our Privacy Policy (such as for fraud
prevention purposes or where we are legally required to share the information).
However, the NPICICA’s broad definitions of “sale” and personal information may deem
the common flow of information in the digital analytics and advertising ecosystem to be
a sale. Like most companies that operate commercial websites and apps, TKKP, LLC
DBA Bossup Virtual Assistants may use online analytics to measure the ways users
engage with our websites and apps. These analytics might tell us how we perform in
online advertising. To provide these analytics and facilitate online advertising, TKKP,
LLC. DBA Bossup Virtual Assistants may use third parties that collect cookies, beacons,
and similar tracking mechanisms.
Where we can reasonably ensure via contract that the third parties described above can
and will use an identifier solely to provide the specific service we requested and will not
use or share the data for other purposes, we will not deem that sharing a “sale” under
the service provider exception. In most cases, we’ve determined that our data analytics
providers that measure the ways users engage with our websites and apps meet this
standard and we will not block the sharing of an identifier with those entities even when
you choose to opt-out through the “Do Not Sell” link.
In some cases, TKKP, LLC. DBA Bossup Virtual Assistants does not control how such
identifiers are used by some third parties (particularly in some cases in the online
advertising ecosystem), and so we can’t determine that all sharing with third parties in
these cases fall within the service provider exception under the law. As a result, we are
currently treating our sharing with some of these third parties as a “sale” under the
NPICICA.
What happens when I tell TKKP, LLC not to “sell” my personal information?
When a user makes the “Do Not Sell” choice, we will attempt to block further sharing of
the covered identifiers with the third parties we engage on those digital properties or any
other entity that does not fall within the service provider exception or the consumer
directed exception.
Whether you opt out of the sale of your personal information or opt out using our
advertising settings here, your information is not used in our advertising program.
How does TKKP, LLC maintain my “Do Not Sell” choice?
You can check the current status of your “Do Not Sell” setting and change that setting
by sending an email to [email protected]. For more information about TKKP,
LLC’S privacy practices and our approach to the NPICICA, please see our Privacy
Policy.[ Annotation]