CCPA – Regarding California Residents
The California Consumer Privacy Act (“CCPA”) provides Consumers (as that terms is defined in the CCPA) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Information that we collect:
We collect Personal Information (“PI”), as defined under the CCPA, which includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular consumer or household.
Please review the below to learn more about (1) the categories of PI that we have collected about consumers over the previous twelve (12) months, (2) the categories of sources from which the PI was collected, (3) the business or commercial purpose(s) for collection and/or disclosure, and (4) the categories of partners with whom we share PI.
Categories of PI we collect:
Website Information: As a visitor, you may be asked or choose to provide us with your personal information on some areas of our Website, such as:
- First name
- Last name
- Telephone number
- Street address
- Online Identifiers: IP address
Categories of Sources from which we collect PI
Below are examples of categories of personal information that we collect, including but not limited to:
Directly from a Consumer, when you provide us with your PI
Ex: When you contact us via our website, email, phone or other similar method
Ex: When you leave a review for us on our Website
Directly or indirectly from vendors, Premier Partners, service providers or other third parties
Ex: Our Customers (in the provision of services)
Ex: Information the Consumer has voluntarily made public
Ex: Information you have shared on social media platforms, specifically publicly visible accounts (i.e. LinkedIn)
From your use, visit or activity on the Website
Ex: Directly (through your submission of information, for instance, to receive a quote)
Ex: Indirectly (through information disclosed by your device or browser, such as IP address)
Purposes for Collection:
To fulfill the purpose(s) for which the information was collected/provided
Ex: To provide you with a quote
Ex: To provide you with information, products, or services you have requested from us or that may be of interest to you
Ex: To provide customer service and support
To improve our website, services and products, through testing, research, analysis and product development
For security purposes, including to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity and availability of your PI and to allow only the appropriate use of your PI
To comply with all applicable legal obligations, including, but not limited to, the CCPA.
Retaining Your PI:
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Categories of Partners with Whom We Share Your PI:
- Service Providers
- Premier Partners, who may share your PI with their vendors, contractors, employees, agents or others
- Affiliates/Subsidiaries and Related Entities
- Contractors to whom you or your agents authorize us to disclose your PI in connection with products or services we provide to you
- External advisors, such as auditors or outside legal counsel
- Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
Your California Rights:
The CCPA provides individuals with various privacy-related rights (“Rights”) relating to their PI. This section provides you with information regarding these Rights.
The CCPA provides a Consumer with the right to opt-out of the sale or share (as defined under the law) of his/her PI. We do not sell PI, and thus do not provide you with a mechanism for opting out.
Right to a Notice: At or before the point of collection of PI, Consumers and other individuals residing in the State of California are entitled to a notice that provides the categories of PI collected about them, and the purposes for that collection.
Right to Know: A Consumer has the right to request information regarding our collection, disclosure, sale, share, and/or use of their PI over the previous twelve (12) months. A Consumer may request that we disclose:
Categories of PI that we have collected about you;
- Categories of sources from which your PI is collected;
- Categories of PI about you that we have sold, shared, or disclosed for a business purpose;
- Categories of to whom the PI was sold, shared, or disclosed for a business purpose;
- The business or commercial purpose for collecting or selling PI; and
- Specific pieces of PI that we have collected about you.
When providing you with your information electronically, we will, to the extent possible, deliver the information in a portable manner that allows you to transfer the information to another entity.
We may reject your request to know if your identity cannot be verified (your request is not a verifiable consumer request), or if the information has already been provided twice within a twelve (12) month period. We may also refuse to provide you with specific pieces of information that we have collected about you if disclosure creates a substantial, articulable, and unreasonable risk to the security of that PI, or the security of our systems.
Right of Deletion: A Consumer has the right to request the deletion of any PI that we collected from them, or that we maintain about them. Following our receipt of your verifiable consumer request, we will delete your PI, subject to the exceptions permitted under the CPRA, and any legal obligations that we have to retain that information.
Right to Non-Discrimination: We will not discriminate against a Consumer in response to the decision to exercise any of the privacy rights granted to you under the CPRA.
Asserting Your Rights – Submitting a Request to Know or Delete:
As previously stated, we may reject your request if we cannot verify your identity. Please follow the instructions below and provide the requested information to allow us to adequately address your request.
You may submit your request via email at email@example.com. The subject of the email should include your full name, email address, phone number, and the date the original request was submitted. We will reply within 20 business days detailing which of our Premier Partners received your information.
Authorized Agents: You may exercise your right to know or your request for deletion of your PI, through the use of an authorized agent. A request from an authorized agent on your behalf will only be accepted if the authorized agent provides us with satisfactory written proof they are authorized to act on your behalf.