SK Global Entertainment Inc. California Privacy Notice
Effective Date: February 6, 2023.
This California Privacy Notice (“Notice”) applies to California residents as a supplement to SK Global Entertainment Inc.’s and its affiliates’ and subsidiaries’, including, without limitation, Critical Content Enterprises, LLC and its affiliates’ and subsidiaries’ (“Company” “us” “we” “our”) other privacy policies or notices. In the event of a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California residents and their rights under California law, including the California Consumer Privacy Act and its amendment, the California Privacy Rights Act (“CCPA”). To learn more about our general privacy practices, please review our Privacy Policy. To learn more about our privacy practices with respect to employment-related information collected from California residents pursuant to the CCPA, please review our California Employee Privacy Policy.
This Notice covers our collection, use, disclosure, and sale of California residents’ “Personal Information” (“PI”) as defined by the CCPA, whether such PI is collected through our websites and applications, including https://skglobalentertainment.com/ and https://www.criticalcontent.com/ and its related websites, apps, and other web-connected services (the “Site”), as well as through any other channels, whether online or offline. This Notice also covers rights California residents may have under the CCPA, as well other notices to Californians as may be required by other laws.
We provide this Notice to comply with applicable privacy laws, including the CCPA. The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of PI, as well as rights to access, correct, delete, and restrict the sale, use, and disclosure of certain PI we collect about them, unless exceptions apply. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by emailing us using the information provided in the Your Privacy Rights section below.
Consistent with the CCPA, publicly available information is also not treated as PI under the CCPA, so this notice is not intended to apply to that data.
To aid in readability, in some places we have abbreviated or summarized CCPA terms or language. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.
If you are a visually impaired individual, an individual with another disability, or an individual seeking support in another language, you may access this Notice by emailing us at info@skglobalent.com.
You can click on the following links to navigate to the different sections in this Notice.
We may collect, or have collected, the following types of PI about California residents over the past twelve (12) months, and use and share it as set forth below.
| Category of PI | Examples of PI |
|---|---|
| 1. Identifiers | This may include but is not limited to: first name, last name, account name or social media handle, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, Social Security numbers, passport numbers, or other government identification numbers, or other similar identifiers. |
| 2. Personal Records | This may include information such as: first name, last name, postal address, telephone number, occupation, company/organization, dietary preferences, or travel preferences. |
| 3. Personal Characteristics or Traits | This may include, but is not limited to: gender or gender identification, race or ethnicity, age, marital status, education level, income level and other income-related information, homeownership and dwelling information, household size, number of children, language preferences, and date of birth. |
| 4. Commercial Information | This may include, but is not limited to: products and services that you have purchased, obtained, or considered, the likelihood that you may purchase, obtain, or consider certain products or services, and the quantity, qualities, and monetary value associated with your purchases. |
| 5. Internet Usage Information | This may include, but is not limited to: browsing time, website history, and information regarding your interaction with an Internet Web site, application, or advertisement. |
| 6. Geolocation Data | This may include, but is not limited to: general physical location. |
| 7. Sensory Data | This may include, but is not limited to: occupation, company/organization, title, roles, and industry. |
| 8. Professional or Employment Information | This may include, but is not limited to: profiles about consumers reflecting the consumer’s preferences, behavior, attitudes, household information, and abilities. |
| 9. Inferences from PI Collected | This may include, but is not limited to: profiles about consumers reflecting the consumer’s preferences, behavior, attitudes, household information, and abilities. |
Please note that because of the overlapping nature of certain of the categories of PI identified above, some of the PI we collect may be reasonably classified under multiple categories.
Sensitive personal information. Certain of the PI that we collect, as described above, may constitute “sensitive personal information” (or “SPI”) under California law, including:
As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.
Additional business purposes include sharing PI with third parties for other than a sale or one of the foregoing business purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, and to the consumer or other parties at the consumer’s request, for the additional purposes explained in Section 2 of our Privacy Policy, and to assignees as part of a merger or asset sale (“Other Business Purposes”).
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed business purposes. Our vendors may themselves engage services providers or subcontractors to enable them to perform services for us consistent with those same purposes.
The Sensitive Personal Information that we collect as described in Section 1 above may be used for any of the above purposes.
In addition, we may collect, retain, and use PI for the purpose of sharing it as set forth in the next section.
We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; (iii) whether there is a privacy right for which the personal information has been exercised (such as a request to delete); and (iv) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
We may disclose PI to our service providers, other vendors, and/or affiliates. In some cases, we may have “sold” or “shared” PI to our Campaign Partners predating 2020, however we do not currently “sell” or “share” PI as those terms are defined by the CCPA. These categories are as follows:
| Categories of PI | Categories of Recipients |
|---|---|
| 1. Identifiers | Business Purpose Disclosure: Campaign Partners and Service Providers |
| 2. Personal Records | Business Purpose Disclosure: Campaign Partners and Service Providers |
| 3. Personal Characteristics or Traits | Business Purpose Disclosure: Campaign Partners and Service Providers |
| 4. Internet Usage information | Business Purpose Disclosure: Service Providers |
| 5. Geolocation Data | Business Purpose Disclosure: Service Providers |
| 6. Sensory Data | Business Purpose Disclosure: Campaign Partners and Service Providers |
| 7. Professional or Employment Information | Business Purpose Disclosure: Campaign Partners and Service Providers |
| 8. Inferences from PI Collected | Business Purpose Disclosure: Campaign Partners |
Company does not have any actual knowledge of “selling” or “sharing” PI, as those terms are defined by the CCPA, from California residents under 16 years of age.
If you are a California resident, you have the right to make the following requests under applicable California law in relation to your PI, subject to certain exceptions:
How to submit a request. You may exercise any of the rights described in this section by emailing us at info@skglobalent.com or by calling (424) 230-5900.
As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the California resident about whom we collected PI. To verify you, you must provide us with your first name, last name, and email address. These rights are also subject to various exclusions and exceptions under applicable laws.
Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect PI from any person under the age of 13.
We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
Authorized agent requests. If you choose to submit a request through an authorized agent, we require you to:
If the authorized agent has a power of attorney issued under California Probate Code sections 4000 to 4465, then the written agreement is not necessary. Pursuant to Probate Code Sections 4121 and 4122, a power of attorney is only valid if it is notarized or witnessed by two adults other than the attorneyinfact. Where witnesses are used rather than a notary, we require verification of the witnesses’ identities, and verification that they in fact witnessed the appointment. The power of attorney must be sufficiently broad, or specific, to establish agency to make a CCPA request. We are entitled to reject any request submitted through a power of attorney if the attorneyinfact cannot reasonably verify the validity of the power of attorney.
The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to info@skglobalent.com or by calling (424) 230-5900.
In addition to CCPA rights, certain Californians are entitled to certain other notices, including:
For more information on your California privacy rights email us or call us at (424) 230-5900.