California Privacy Notice
Last updated July 1, 2020
California residents should be aware of certain rights granted under the California Consumer Privacy Act of 2018 (as amended, the "CCPA"). This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P ("GLB Rights"), GLB Rights shall apply.
What information do we collect about you?
The types of personal information we collect about you depends on the nature of your interaction with us.
The categories of personal information we may have collected from you over the last (12) months include the following:
- Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
- Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
- Commercial information, such as account data;
- Professional or employment-related information;
- Education information;
- Internet or other electronic network activity information, such as information regarding your use of our Website in anonymous form (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.
We do not knowingly collect or solicit personal information from anyone under the age of 18.
How do we use your personal information?
We may use your personal information for one or more of the following business purposes:
- To perform services for you.
- To improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To communicate with you, including responding to requests for information submitted by you through our Website.
- To keep a record of your relationship with us.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of our services and compliance.
- To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Who do we share your personal information with?
We do not sell any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as required by law or regulation and to affiliates and service providers.
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we share the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
If you would like to discuss or exercise your rights under the CCPA, or have questions regarding our processing of your personal information, please contact us at firstname.lastname@example.org or (503) 275-9675.
California law requires us to contact you to confirm receipt of your request under the CCPA. To verify your request, we will match information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information in order to verify your request.
You may also designate an authorized agent to make a request under the CCPA on your behalf. If an authorized agent submits a request on your behalf, we will contact you to verify that they have authority to represent you.