Last updated: October 2026
California Privacy Notice
Applies only to residents of California, and only to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), applies to the Emanay Group. It supplements the Privacy Policy (Part 2).
1. Introduction
This notice explains how the Emanay Group collects, uses, discloses and keeps personal information of California residents, and how they can exercise their rights. It covers consumers (clients, prospects, website and channel users) and our employees, contractors and job applicants.
2. Key terms
- Personal information — information that identifies, relates to or could reasonably be linked with a particular California resident or household.
- Sensitive personal information — for example government ID numbers, account log-ins, financial account numbers with access codes, precise geolocation, and immigration status.
- Sell / share — disclosing personal information to a third party for money or other value, or for cross-context behavioural advertising.
- Service provider / contractor — a company that processes personal information for us under a contract restricting its use.
3. Personal information we collect
| Category | Examples | Consumers | Employees, contractors and applicants |
|---|---|---|---|
| Identifiers | Name, email, phone, postal address, account name, IP address | Collected | Collected |
| Personal records (Cal. Civ. Code 1798.80) | Signature, bank account, tax ID, passport and driver’s licence numbers | Collected | Collected |
| Protected characteristics | Age, citizenship, marital status | Collected where needed for an Engagement (for example E-2 or estate planning) | Collected where the law requires (for example work-eligibility checks) |
| Commercial information | Engagements, services purchased, payment history | Collected | Not collected |
| Biometric information | Fingerprints, face or voice prints | We do not collect | We do not collect |
| Internet and network activity | Activity logs in the Emanay Products, browsing on our sites | Collected | Collected, including monitoring logs on Emanay systems |
| Geolocation | Approximate location from IP address | Collected (approximate only) | Collected (approximate only) |
| Audio and visual | Call recordings with consent, photos supplied | Collected with consent | Collected with consent |
| Professional or employment information | Employer, role, work history | Collected for clients’ representatives | Collected, including background checks where lawful, payroll and compensation |
| Education information | Degrees, certifications | Not collected | Collected for applicants and staff |
| Inferences | Preferences drawn from other data | We do not create profiles | We do not create profiles |
| Sensitive personal information | Government IDs, account numbers, credentials, immigration status | Collected only where needed for an Engagement, verification or law | Collected for payroll, tax and work eligibility |
4. Sources
Directly from you; from the client you work with or for; from our team members, associates, referral partners and creators; from integrations, banks and payment processors you connect; from identity-verification and background-check providers; and from public sources.
5. How and why we use personal information
| Purpose | Legal reason |
|---|---|
| Provide the Emanay Products and perform Engagements | Contract with you or the client |
| Verify identity and meet KYC/AML, tax and record-keeping rules | Legal obligation |
| Billing, statements, attribution and compensation | Contract; legitimate business purpose |
| Security, fraud and scraping prevention, activity logging | Legitimate business purpose |
| Hiring, payroll, benefits and managing staff | Employment or contractor relationship; legal obligation |
| Improving our services with de-identified or aggregated data | Legitimate business purpose |
| Promotional communications | Your consent or our legitimate interest, with opt-out |
6. Promotional communications
You can opt out of newsletters and marketing emails at any time using the link in each message, and of texts by replying STOP. We never sell or share your personal information for others’ marketing.
7. Who has access
Only people whose role requires it: our team members, associates working on your Engagement, and service providers and contractors bound by contract. Each client’s information is kept separate.
8. Sold or disclosed for a business purpose
We do not sell or share personal information and have not done so in the last 12 months. In the last 12 months we disclosed the categories in section 3 for business purposes to service providers and contractors (hosting, storage, email, payments, e-signature, accounting software, identity verification, AI providers), to professionals clients authorise, and to authorities where required.
9. Where your information is held
On servers in the United States operated by us and our service providers.
10. How long we keep it
- Client and consumer accounts: while the account or Engagement is active, and afterwards for the periods the law and our record-keeping duties require.
- Applicants not hired: 1 year after the hiring decision.
- Employees and contractors: up to 7 years after they leave.
- Activity logs: at least 7 years.
11. Security
We use the protection measures described in the Privacy Policy, Part 2, section 10.
12. How to exercise your rights
You may ask to know, access, correct, delete or port your personal information, and to limit use of sensitive personal information, and you will not be discriminated against for doing so.
- How: email legal@emanay.io, or write to us at the address below.
- Limits: you may make up to two access or portability requests in any 12-month period.
- Verification: we will match the information you give us with what we hold, and may ask for more for sensitive requests.
- Authorised agents: may act for you with signed permission; we may still verify your identity directly.
13. Changes
We will update this notice when our practices change and post the date of the latest version.
14. Contact
legal@emanay.io · Emanay Inc., 1221 Brickell Avenue, Suite 900, Miami, Florida 33131.