Starting January 1, 2020, a new privacy law, the California Consumer Privacy Act (“CCPA”) will govern how businesses handle the personal information of California residents. These FAQs explain how DojoMojo will continue to provide services to our customer brands. DojoMojo does not have a direct relationship with consumers, but will help customer brands comply with their CCPA obligations as described below.
DojoMojo is a service provider to our customer brands. A primary feature DojoMojo provides to customers is our ability to derive consumer insights by analyzing data across customers. DojoMojo does not sell information to any third parties and only processes information to serve our customers.
When entering a sweepstakes, a consumer is entering into a direct, first-party relationship with each customer brand on the sweepstakes campaign (regardless of who is hosting the sweepstakes or which brand introduced the consumer to the sweepstakes). DojoMojo facilitates this process, but has no relationship with the consumer.
ESP & Payment Processor Integrations
When customer brands connect their ESP and/or Payment Processors, DojoMojo may analyze data across customers to create insights to improve the services customers receive. For example, DojoMojo may develop insights from information obtained across brands to prioritize marketing communications sent on behalf of a customer brand. Customers will not have access to another brand’s consumers’ personal information, and DojoMojo will only use the insights to provide the services.
Privacy Updates for Customer Brands
Key to the value of the services DojoMojo provides to customers is our ability to provide insights across our brands. Customer brands benefiting from the platform’s core features, such as brand matching and performance tracking may be, under the definition of CCPA, “selling” data to other brands. This data comes in the form of recommendations and insights derived from consumers’ purchasing histories. DojoMojo will never share among brands personal information like consumers’ names, contact information, or purchases.
Customer brands should (a) notify consumers how the brand uses and discloses consumers’ information and (b) provide California consumers the appropriate rights under the CCPA.
Access/Delete Request Process via Customer Brands
As a service provider, DojoMojo will assist customer brands in responding to CCPA access and deletion requests.
- If a customer brand receives a CCPA request to access or delete personal information, the customer brand must verify the authenticity of the request before making an ACCESS/DELETE request to DojoMojo.
- Once verified, the customer brand will be able to submit the ACCESS/DELETE request to DojoMojo via a dedicated web form. The form will ask:
- Brand name
- Brand contact Information (the brand representative submitting the request, email, phone number)
- Requestor’s email address
- The request type (i.e., access or delete)
- Verification that the brand has verified the requestor’s identity
- Upon submission, we will perform a rapid database check, and if the email address does not exist in the brand’s record, will send an automated email to the customer brand confirming we have no data.
- If the email does exist, the request will be routed to our engineering team, which will process the request and respond to the customer brand with the appropriate action and confirmation.
CCPA Compliance Summary
- DojoMojo is a service provider. We process personal information for the sole benefit of our customer brands.
- When entering a sweepstakes, a consumer is entering into a direct relationship with each brand on the sweepstakes (regardless of who is hosting the sweepstakes or which brand introduced the consumer to the sweepstakes). DojoMojo facilitates this process, but has no relationship with the consumer.
- When brands connect their ESP and/or Payment Processors, DojoMojo may create insights to improve the services by analyzing data across customer brands. Customer brands cannot access another customer brand’s consumers’ personal information.
- DojoMojo does not sell consumer information and therefore does not have a Do Not Sell function.
- Brands should submit access/delete requests through DojoMojo’s CCPA Request form found in Brand Settings.