California Consumer Privacy Act Notice
The California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”) provides certain verified California residents the following rights. For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
Your CCPA Rights
Information Access Rights. As a California resident you have the right to request that we disclose certain information upon request about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you. You may make Information Access Requests up to twice during a 12 month period. Once we receive and confirm your verifiable request, we will disclose to you:
- Information Collection Practices: the categories of personal information we collected about you, the categories of sources of such information, our business purpose for collecting or sharing such information, and whether the information was disclosed for a business purpose, sold or shared.
- Information Disclosure practices: the categories of personal information sold or shared with the category of third party recipients and the categories of personal information that we disclosed for a business purpose.
- Data Portability: a copy of the specific personal information we have collected about you during the prior 12 months, or at your option, since January 1, 2022. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy.
Information Deletion Rights. California residents have the right at any time to request that we delete any of your personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations.
Information Correction Rights. California residents have the right at any time to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account.
- Do Not Sell My Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. We do not sell your personal information.
- Do Not Share My Personal Information. You have the right to opt out of having your personal information shared with others for cross-context or behavioral advertising purposes. This does not include using your interactions with us or information that you provide to us to select advertisements to show you. We do not share your personal information with third parties for cross-context or behavioral advertising purposes.
- Limit Processing of Sensitive Personal Information. You have the right to tell us not to process or disclose Sensitive Personal Information for any purpose other than legally permitted purposes and the purposes for which it was originally collected. The following are the CCPA permitted purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer's current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
- To perform services on behalf of our business.
- To verify or maintain the quality or safety of products or services that we own or control, and to improve, upgrade, or enhance such products or services.
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
We only process Sensitive Personal Information for legally permitted purposes or the purpose for which we originally collected it.
Exercising your CCPA Rights
Access, Correction and Deletion: In order to make a request for access, correction and deletion rights California residents may contact us by calling us toll-free at [Phone Number] or by emailing us at [Email Address]. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. Any disclosures we provide will only cover the 12-month period preceding receipt of your request, but you may request that expand the 12-month period to cover information collected since January 1, 2022, and we will honor that expanded request unless doing so would involve a disproportionate effort. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
We do not sell your personal information for monetary or other valuable consideration. We do not share your personal information with third parties for cross-context behavioral marketing purposes. We do not process of disclose your Sensitive Personal Information for purposes beyond those for which it was originally collected.
Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorize the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
Non-Discrimination. We will not discriminate against you as a result of your exercise of any of these rights.
Information Collected, Sources, and Business Purpose for Collection
During the past 12 months we collected the following categories of information about California residents including employees, customers, vendors and others. Not all information is collected about all individuals. Information is collected directly from the individual, from third parties such as staffing partners or references, or by us for security or employee/vendor oversight purposes.
- Identifiers (such as name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver's license number, passport number, unique personal identifier, IP address)
- Protected Information (name with financial account, medical, health, and health insurance information, user name and password)
- Protected anti-discrimination classification information (race, gender, ethnicity, religion)
- Commercial information (transaction history, products/services purchased, obtained or considered, product preference)
- Electronic network activity (browsing or search history, website interactions, advertisement interactions, activity using company computers, devices and systems)
- Audio, video or similar information (customer service calls, security monitoring)
- Professional, educational or employment related information
- Sensitive Personal Information (social security, driver's license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation)
- Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.)
Disclosure of Personal Information
During the past 12 months we may have disclosed the following categories of information about California residents for a business purpose to the following categories of third parties. Business purposes are listed above under Use of Your Personal Information. We did not sell or share personal information for cross-context behavioral marketing purposes.
- Identifiers – shared with service providers such as payment processors, employee benefits service providers, shipping partners, mail houses, marketing partners, legal and accounting providers, affiliated companies; may be shared with government regulators or law enforcement on legal request
- Protected information – shared with payment processors, employee benefits service providers.
- Commercial information – shared with affiliated companies for fulfillment purposes, service providers such as shipping partners, payment processors, mail houses, legal and accounting providers.
- Electronic network activity – shared with webhosting provider
- Professional, education or employment related information – shared with employee benefits providers and staffing provider, may be shared with government regulators or law enforcement on legal request
- Sensitive Personal Information – employee/applicant/vendor sensitive personal information may be shared with benefits providers, staffing providers, legal and accounting providers, government regulators or law enforcement on legal request for legal compliance.