Effective: January 1, 2020
Last Revised: September 29, 2020
Disabled consumers who need these disclosures presented in an alternate medium, may contact us at the email address or telephone number listed further below.
Personal Information That We Collect
By providing your personal information to us, asking to be contacted or using us to interact with a third party, you are also specifically directing us to disclose your information to any third-parties listed, along with others who we feel may have information or offers you may be interested in.
We collect personal information directly from you and by observing your interactions on our website which identifies, relates to, describes and/or is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. In the last twelve months we have collected the categories of information listed below. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. The following is an overview of information defined by the CCPA as personal information.
|A. Unique personal identifiers||A real name, account name, address, alias, bank account number, credit card number, email address, debit card number, driver’s license number, insurance policy number, internet Protocol address, passport number, physical characteristics or description, postal address, online identifier, signature, Social Security number, state identification card number, telephone number, unique personal identifier, or other similar identifiers.|
|B. Characteristics of protected classifications under California or federal law||Age (40 years or older), ancestry, citizenship, color, disability (physical or mental), marital status, medical condition, national origin, race, religion or creed, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|C. Commercial information||Products or services considered, obtained or purchased, purchasing or consuming histories or tendencies, records of personal property.|
|D. Biometric information||Activity patterns used to extract a template, behavioral, biological, genetic or physiological characteristics, other identifiers or identifying information eg:, face, finger or voiceprints, gait tendencies, health information like exercise or sleep information, iris or retina scans, keystrokes or other physical patterns.|
|E. Internet or other electronic network activity information||Browsing history, search history, information regarding interaction with advertisements, applications or websites.|
|F. Geolocation information||Physical location or movements including trends.|
|G. Sensory information||Audio, electronic, visual, thermal, olfactory or similar data.|
|H. Professional or employment related information||Past or present job history, performance evaluations.|
|I. Non-public / Private (non-public) educational information protected by the Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Class lists, disciplinary records, financial information, grades, identification codes, schedules, transcripts or other information directly related to a student which is collected by educational institutions or agencies acting on their behalf.|
|J. Inferences or conclusions drawn from personal information||Profiles reflecting an individual’s abilities, attitudes, aptitudes, behavior, characteristics, intelligence, predispositions, preferences, psychological trends etc.|
|K. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A 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.
Some personal information included in this category may overlap with other categories.
Personal information does not include: De-identified or aggregated consumer information, information excluded from the CCPA’s scope (eg: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data). Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994, publicly available information from government records.
We obtain personal information from the following categories of sources
- Client or their agents, directly or indirectly
- Government entities from which public records are obtained
- Third parties, advertising networks, consumer data resellers, data analytics providers, government entities, internet service providers, social networks, operating systems and platforms
- Website interactions from our contact us and other web forms.
How We Use Personal Information regulated by the CCPA
|A. As described upon collection of information||As set forth in the CCPA.|
|B. Complying with the law||Obeying the court, law and government regulations, responding to requests from law enforcement and other governing bodies.|
|C. Fulfill requests, the reason you provided the information||Answering questions, facilitating delivery, fulfilling purchases, providing information on products or services, price quotes, processing payments and transactions, processing product orders, processing returns. This includes, for example, when you make a request online to receive offers via email or telephone, or when you request or agree during one of our phone calls, to be transferred to a third-party product or service seller to receive such offers.|
|D. Maintaining safety and security||Preventing theft of information, products and services as well as technological resources and preventing transactional fraud.|
|E. Personalizing the customer experience||Personalizing your experience to deliver content, product and service offerings relevant to your interests (eg; targeting offers and ads through our website, third-party sites and via email or text messaging –with your consent, where required by law).|
|F. Product development||Product, service and website improvement, research and analysis|
|G. Providing support||Developing and personalizing our products, services and website, investigating and addressing concerns, monitoring and improving responses|
|H. Restructuring||Evaluating or conducing mergers, divestures, reorganization, sale or transfer or assets in the event of bankruptcy, liquidation, etc.|
Sharing Personal Information
We may disclose your personal information to a third party (eg: Service providers and data aggregators) for a business purpose. When we disclose your information for business purposes our contracts state the purpose and requires all parties use personal information for the sole purpose of executing the contract and also that all personal information be kept confidential.
Personal Information Disclosed in the Last 12 Months
In the last twelve months, we have disclosed the categories of personal information below for a business purpose.
Category A: Unique Personal Identifiers
Category C: Commercial Information
Category E: Internet or Other Electronic Network Activity Information
Category J: Inferences or Conclusions Drawn from Personal Information
Category K: Personal Information Categories Listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Personal Information Sold in the Last 12 Months.
In the last twelve months we have not sold personal information for a business purpose. Note that under the CCPA, a business does not “sell” personal information when a consumer uses or directs the business to intentionally disclose personal information or uses the business to intentionally interact with a third party, provided the third party does not also sell the personal information, unless that disclosure would be consistent with the provisions of this title. An intentional interaction occurs when the consumer intends to interact with the third party, via one or more deliberate interactions.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information if they are California residents. The following is an overview of these rights and an explanation of how to exercise them.
- Specific Information Access and Data Portability Rights California residents have the right to request the disclose of what CCPA personal information we have collected about them in the last twelve months and what we have used it for during this time period. To the extent required by the CCPA, when we receive a verifiable consumer request, we will disclose the following information, after verifying your identity, if we can:
- Business or commercial purposes for collecting or selling personal information.
- Categories of personal information collected about you.
- Categories of sources we use to collect personal information about you.
- Categories of third parties we share your personal information with.
- Internet or other electronic network activity information collected or maintained.
- Deletion Request Rights California residents have the right to request that we delete any of the CCPA personal information which we collected about them. After we have received and confirmed your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete your personal information and instruct our service providers to delete your information as well. We may not delete your information if it is required to us or our service providers to do the following:
- Completing the contract or transaction for which we collected the personal information, providing goods or services requested, taking reasonable actions within the scope of our ongoing business relationship with you.
- Finding and resolving defects or errors impacting intended product, service or website functionality.
- Complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.), and other legal obligations.
- Internal processes in alignment with your relationship with us.
- Complying with free speech rights, engaging in free speech, ensuring consumers right to exercise their free speech.
- Identifying security risks, protecting against deceptive, fraudulent, malicious, or illegal activity, or prosecuting individuals involved in such activities.
- Complying with other laws.
- Participating in public or peer-reviewed historical, scientific, or statistical research which is in the public interest and abides by ethics standards, if the information is required to complete the research and you have provided informed consent.
- Exercising Access, Data Portability, and Deletion Rights Only you or someone registered with the California Secretary of State who is authorized to act in your interests may make a request for information or deletion. Once you have made a verifiable consumer request, we will provide your personal information is a portable manner so that you can access it easily. Any information you provide will only be used to verify your identity. You can make a request following the instructions below:
- Use our online Request to Know form, call us or email us using the contact information found at the end of this notice. We will confirm receipt within 10 days and then provide a written response within 45 days. If we require more time (up to 90 days), we will inform you in writing of the reason.
- Provide us with information necessary to verify your identity so that we may release the information to the individual to whom it belongs, or an authorized representative.
- You need not create an account to make requests, but if you have an account and login with us, signing in through our portal with a password serves to verify your identity.
- Provide enough detail in your request that we understand you, can evaluate the request and provide an answer.
- Select the format in which you would like to receive your personal information. This format should be readily accessible and allow you to transport the data to others without issue.
- We will provide access to your personal information for the last twelve-month period or provide an explanation as to who we cannot comply with the request.
- There is no fee to process your verifiable consumer request unless it is excessive. In which case we will inform you of the fee before proceeding.
You will need to prove your identity to us. If you have no password-protected account with us, you will need to provide us with at least 2 data points which we already maintain about you, and possibly other information and a signed declaration under penalty of perjury if the information maintained about you is of a sensitive nature. In some cases, we might not be able to successfully verify your information and in such a case, we will notify you as to why we cannot provide it.
- Personal Information Sales Opt-Out and Opt-In Rights California residents who are sixteen years of age or older have the right to dictate that we do not sell their personal information. If you opt-in to information sales, either verbally or in writing, you may opt-out at any time. Minors are not allowed to use our websites or services and we do not intentionally collect any personal information for or regarding those under the age of eighteen. To opt out please contact us using the contact information found at the end of this notice.
- Financial Incentives & Non-Discrimination Rights To the extent required by the CCPA, we will not discriminate against individuals who choose to exercise any of their rights under the CCPA. Unless allowed by the CCPA, we will not:
- Deny you good or services because you exercised your rights.
- Charge different rates or prices, impost penalties or grant differential discounts for punitive purposes.
- Provide (or suggest) those who exercise their rights a different quality goods or a different level of service.
- We may, however, offer financial incentives to those who provide personal information which may result in variations in price, rates or quality depending on the value of the information provided.
- You must opt-in or provide prior written consent to participate in financial incentive programs and you may revoke this consent at any time.
We do not offer financial incentives to consumers to induce their agreement for us to sell their personal information. Rather, if you do not agree, we might not be allowed to provide your information to third parties who have the quotes, services or other information you have requested. Note that under the CCPA, the “sale” of information does not include the disclosure of information at the consumer’s request.
- Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) provides California residents with the right to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us using the contact information found at the end of this notice.
Changes to Our Privacy Notice
We reserve the right to amend this notice of privacy at any time and at our sole discretion. When changes are made, we will post a notice on the main website and the date the changes take effect. Continued use of this website indicates your acceptance of these changes.