This Privacy Notice for California Residents ("Notice") supplements the information contained in the other sections of this Policy and only applies to consumer users of our Sites that are residents of the State of California ("Consumer(s)" and in this Section "you" and "your"). We have adopted the terms of this Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and its related regulations. Terms used in this Notice have the same meanings as defined in the CCPA.
We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual Consumer, household, or device. We have collected the following categories of Personal Information from Consumers within the last twelve months:
The following examples are taken directly from the CCPA, where we indicate that a category is collected, we collect at least one of the example items from each category.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | YES |
| B. 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. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, 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). | No |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
We obtain the categories of Personal Information listed above from the following categories of sources:
Personal Information we collect may be shared with service providers who provide certain services on our behalf, including but not limited to identity verification, fraud prevention, business intelligence, customer relationship management, bill collection, payment processing, marketing, hosting, and other common technology services. Our contracts with these service providers dictate that they only use Consumer information in connection with the services they perform for us and you consent to our sharing of information with these parties by using our Sites subject to this Policy.
In the preceding twelve months we have disclosed the following categories of Personal Information to our third-party service providers for a business purpose:
We disclose Consumer Personal Information for our business purposes to the following categories of third parties:
In the preceding twelve months we have sold the following categories of Personal Information to Partners and/or Contractors:
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights via a Verifiable Consumer Request.
We are unable to respond to requests when we cannot verify your identity or authority to make the request. Personal Information provided in a Verifiable Consumer Request will only be used to verify the requestor’s identity or authority to make the request and to comply with the request. You are not required to create an account with us to submit a Verifiable Consumer Request. We can only honor and respond to Verifiable Consumer Requests related to data that we hold directly in our systems. Personal Information shared with or sold to Partners, Contractors, or other third parties is subject to their Verifiable Consumer Request process and such request should be submitted directly to those Partners, Contractors, and third parties.
Upon receipt of a Verifiable Consumer Request we will disclose the following information
Personal Information is retained by us for various time periods, we may not be able to fully respond to what might be relevant for the twelve months prior to receipt of the Verifiable Consumer Request.
California Civil Code Section 1798.83 entitles Consumers to request information concerning whether a business has disclosed certain information about you to any third parties for the third parties’ direct marketing purposes. Consumers who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us using the Contact Information below.
Deletion Requests: The CCPA provides Consumers with the right to request that we delete any Personal Information that we collected about you, subject to certain exceptions. Upon receipt and confirmation of your Verifiable Consumer Request we will delete your Personal Information from our records, unless an exception applies, and direct our service providers to similarly delete your Personal Information from their records.
In addition to submitting a Verifiable Consumer Request, requests to delete your Personal Information can be made by submitting this form.
Personal Information Sales Opt-Out and Opt-In Rights:
The CCPA provides Consumers the right to opt-out of the sale of Personal Information about their or their household, for example their name, postal or email address, and other personally identifying information. You need not be physically present in California exercise this right, provided that you have a current California residence. This right is subject to certain exemptions. For example, it does not apply to information that we share with certain third-party service providers that are performing business functions for us or on our behalf.
To exercise the right to opt-out, you, or your authorized representative, may submit an opt-out request to us using this form, or by emailing or calling us at the contact information provided below. You are not required to create an account with us to submit an opt-out request. Personal Information provided in an opt-out request will only be used to verify the requestor’s identity or authority to make the request and to comply with the request.
Following the fulfillment of your opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Information sales. However, you may opt-in to Personal Information sales at any time, by contacting us using any method in the Contact Information section.
Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA: we will not deny you goods or services; charge you different prices or rates for goods or services, including through allowing discounts or other benefits, or imposing penalties; provide you a different level or quality of good or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We have implemented reasonable security measures designed to secure your Personal Data from accidental loss, unauthorized access, use, alteration and disclosure, however we do not provide any guarantee that your Personal Data will remain secure. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites. All information you provide to us is stored on our service providers’ servers which utilize industry standard security controls; however, we do not have control over and will not be liable for third parties’ security processes. Any transmission of information or Personal Data is at your own risk
Our services are neither directed at nor intended for direct use by individuals under the age of 18 or the age of majority in the jurisdiction where they reside. Further we do not intentionally gather information about such individuals. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Sites if you are not the age of majority in your jurisdiction unless you have the consent of your parent or guardian.
We operate in the United States. Our Sites may be accessed from anywhere, and users outside of our target United States markets may submit their Personal Data to us via forms, comment fields, or other input mechanisms. If you are accessing the Sites from outside the United States, or submitting your Personal Data to us from outside the United States, your Personal Data may be transferred to, stored, or processed in the United States and maintained on computers or servers located outside of your state, province, country, or other jurisdiction where the privacy laws may not be as protective those in your jurisdiction. By accessing our Sites, you understand and consent to the transfer of your information to the United States and to those third parties with whom we share it as described in this Policy, whether or not we can currently serve your jurisdiction.
Web technology information: This may be personal or non-personal information and collected by us or third parties under contract with us. We use two third party services: ActiveProspect’s TrustedForm Script is used to independently document users’ consent to be contacted. The TrustedForm Script is embedded on this website and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser. For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at ActiveProspect. Similarly, we utilize Jornaya’s LeadiD script which is embedded on this website and also collects information such as browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, IP address and number of clicks and tracks users’ movements around the site (including the capture of visual snapshots of the user’s activity on the site). To review Jornaya’s data use and collection policies and practices, please visit: Jornaya. The information collected from this technology is combined with other aggregate data to issue a unique identifier for that site visit.
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