AltadenaWILD Incorporated (AW), a 501(c)(3) charitable organization and public benefit corporation in California, is sponsoring an online petition pertaining to an emerging land use issue in Los Angeles County. Petition signers are asked to provide the following information:

(1) First and Last Names, (2) City/Town, (3) Zip Code, and (4) Email address.

There is no requirement to provide a residential (street) address. These data are also utilized by AW to keep the citizen-signers informed about relevant news and developments through an emailed newsletter. Pursuant to guidance from the Los Angeles County Board of Supervisors, Fifth District, there is no minimum age limit for signing a petition pertaining to land use within the County. Nonetheless, AW has introduced the following requirements for online petition signers:

(i) they reside in Los Angeles County, and (ii) they are at least 14 years of age.

The first requirement follows from the fact that this land-use issue is likely to be decided by the Los Angeles County Regional Planning Commission and/or Board of Supervisors. The second requirement follows from a desire to accommodate the passion of high-school students regarding matters of the environment and conservation, while balancing the societal goals of protecting minors/children. There are two relevant California State laws governing the collection/use of personally identifiable information and the design of websites that may attract children (the state defines a “child” as someone under the age of 18 years).

[Legal requirements pertaining to the federal Children’s Online Privacy Protection Act (COPPA) apply only to children under 13 years of age.]

PRIVACY PROTECTION POLICIES

In 2003, the State of California has passed legislation known as the California Online Privacy Protection Act (CalOPPA). The law applies to operators of commercial websites or online services that collect “personally identifiable information through the Internet about individual consumers residing in California.” The above cited data collected on the AW website constitute“personally identifiable information” (PII) in accordance with Section 22577 of Chapter 22 of the California Business and Professions Code. As such, AltadenaWILD is posting this Privacy Protection Policy in compliance with Section 22575 of the above cited State Code and with CalOPPA.

The State requirements are listed in bold font; the AW responses are in regular font.

22575(b)

(1) Identify the categories of personally identifiable information (PII) that the operator collects through the Web site or online service about individual consumers who use or visit its commercial Web site or online service and the categories of third-party persons or entities with whom the operator may share that personally identifiable information.

The collected PII are: first and last names, city/town, Zip Code, and email address. There are no third-party persons or entities with whom AltadenaWILD will share these PII.

(2) If the operator maintains a process for an individual consumer who uses or visits its commercial Web site or online service to review and request changes to any of his or her personally identifiable information that is collected through the Web site or online service, provide a description of that process.

Not applicable.

(3) Describe the process by which the operator notifies consumers who use or visit its commercial Web site or online service of material changes to the operator’s privacy policy for that Web site or online service.

Any material changes to AltadenaWILD’s Privacy Policy are communicated to petition signers through a posting on the relevant AW website page(s). AltadenaWILD may also notify petition singers through a mass mailing to the provided email addresses.

(4) Identify its effective date.

The effective date for the Privacy Policy was 2023 February 21.

(5) Disclose how the operator responds to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services, if the operator engages in that collection.

Not applicable.

(6) Disclose whether other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when a consumer uses the operator’s Web site or service.

No other parties may collect PII about a petition signer over time and across different Web sites.

DATA PROTECTION IMPACT ASSESSMENT

The California legislature passed the California Age-Appropriate Design Code Act (AB2273) in the 2021-22 session. The Act was subsequently enacted into law by the Governor’s signature on 2022 September 15 and becomes effective on 2024 July 1. This new law augments the California Privacy Rights Act of 2020.

The law requires that a business “before any new online services, products, or features are offered to the public, complete a Data Protection Impact Assessment, as defined, for any online service, product, or feature likely to be accessed by children and maintain documentation of this assessment as long as the online service, product, or feature is likely to be accessed by children.” While there is ambiguity on whether AltadenaWILD constitutes a ‘business,” AW elects to demonstrate its compliance with the provision of the law. This requires a Data Protection Impact Assessment (DPIA), with contents specified in Section 1798.99.31(1)(B), Title 1.81.47 of the California State Code.

The State requirements are listed in bold font; the AW responses bare in regular font.

(i) Whether the design of the online product, service, or feature could harm children, including by exposing children to harmful, or potentially harmful, content on the online product, service, or feature.

The AltadenaWILD (AW) website is devoted to conservation and environmental concerns. It includes an online petition pertaining to a local land-use issue. By any rational assessment, the website design and information contained therein introduces no harmful or potentially harmful content to children.

(ii) Whether the design of the online product, service, or feature could lead to children experiencing or being targeted by harmful, or potentially harmful, contacts on the online product, service, or feature.

By any rational assessment, the AW website and information contained therein introduces no possibility of children experiencing or being targeted by harmful, or potentially harmful, contacts. Since AW does not share personally identifiable information with any third-party vendors, there is no risk of children being targeted by harmful information.

(iii) Whether the design of the online product, service, or feature could permit children to witness, participate in, or be subject to harmful, or potentially harmful, conduct on the online product, service, or feature.

By any rational assessment, the AW website and information contained therein cannot permit children to witness, participate in, or be subject to harmful, or potentially harmful, conduct.

(iv) Whether the design of the online product, service, or feature could allow children to be party to or exploited by a harmful, or potentially harmful, contact on the online product, service, or feature.

By any rational assessment, the AW website and information contained therein introduces no possibility of children to be party to or exploited by a harmful, or potentially harmful, contact on the online product, service, or feature. Since AW does not share personally identifiable information with any third-party vendors, there is no risk of children being exploited by harmful information.

(v) Whether algorithms used by the online product, service, or feature could harm children.

There are no algorithms used by an AW product, service, or feature.

(vi) Whether targeted advertising systems used by the online product, service, or feature could harm children.

There is no targeted advertising used by an AW product, service, or feature.

(vii) Whether and how the online product, service, or feature uses system design features to increase, sustain, or extend use of the online product, service, or feature by children, including the automatic playing of media, rewards for time spent, and notifications.

AW uses no system design features to increase, sustain, or extend use of the online product, service, or feature by children, including the automatic playing of media, rewards for time spent, and notifications from its website.

(viii) Whether, how, and for what purpose the online product, service, or feature collects or processes sensitive personal information of children.

The AW website offers the opportunity to Los Angeles County residents at least 14 years of age to sign an online petition pertaining to an imminent land-use issue. Such a petition asks for first/last names, town/city, Zip code, and email address. These data will only be shared – at the appropriate time – with the Los Angeles County Board of Supervisors, the elected officials who are responsible for major land-use decisions in the County.

Attested as being factually correct by AltadenaWILD, Incorporated President Michael D. Bicay, July 2023.