LAST UPDATED: December 16, 2019
EFFECTIVE: January 1, 2020
What is Personal Information?
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. However, the CCPA generally does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
Our Collection, Use, and Disclosure of Personal Information.
We collect Personal Information about California residents in a variety of contexts. For example, we collect Personal Information about California residents who: apply for employment with us or who are our employees, vendors, contractors, or similar personnel; are beneficiaries, dependents, or emergency contacts of our employees; visit our locations in California; we market to; and contact us through our website. The Personal Information that we collect, use, and disclose about a California resident depends on our relationship or interaction with that person.
In the past 12 months, we collected and disclosed for our business purposes the following categories of Personal Information about California residents:
- Identifiers, such as name and Social Security number.
- Personal information, as defined in the California safeguards law, such as contact information and financial information.
- Characteristics of protected classifications under California or federal law, such as age and marital status.
- Commercial information, such as transaction and account information.
- Biometric information, such as fingerprints and voiceprints.
- Internet or network activity information, such as browsing history and interactions with our website.
- Geolocation data, such as device location.
- Audio, electronic, visual, thermal, olfactory, and similar information, such as call and video recordings.
- Professional or employment-related information, such as work history and prior employer.
- Education information, such as school and graduation date.
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, a person’s preferences and characteristics.
In the past 12 months, we collected Personal Information about California residents from the following categories of sources:
- California residents directly.
- Consumer data resellers.
- Service providers.
- Government entities from which public records are obtained.
- Consumer reporting agencies.
In the past 12 months, we disclosed for our business purposes Personal Information about California residents to the following categories of recipients:
- Service providers.
- Government entities.
The purposes for which we use the Personal Information that we collect depend on our relationship or interaction with a specific California resident. We may use Personal Information: to operate, manage, and maintain our business; to provide our products, services, and website; for our employment, employee benefits, and vendor management purposes; to accomplish our business purposes and objectives; to fulfill or meet the reason you provided the information; as described to you when collecting your Personal Information; and as otherwise set forth in the CCPA. For example, we use Personal Information to: support, personalize, develop, market, and provide our products, services, and website; process your requests, purchases, transactions, and payments; create, maintain, customize, and secure your account with us; provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via mail, social media, email or text message (with your consent, where required by law); conduct testing, research, data analysis, and product development, including to develop and improve our products, services, and website; detect and prevent fraud; perform identity verification; maintain the safety, security, and integrity of our products, services, website, databases and other technology assets, and business; maintain our facilities, systems, and infrastructure; conduct risk and security control and monitoring; perform accounting, audit, and other internal functions, such as internal investigations; sponsor and administer employee benefits and benefit programs; contact others in case of an emergency; respond to law enforcement requests; comply with law, regulations, legal process, court orders, and internal policies; maintain business records; exercise and defend legal claims; and evaluate or conduct a corporate transaction such as a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of our assets or business.
Requests Under the CCPA.
If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information that we collected about you and the categories of sources from which we collected such Personal Information.
- The business or commercial purpose for collecting Personal Information about you.
- The categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information (if applicable).
- The specific pieces of Personal Information we collected about you.
If you are a California resident, you may also request that we delete Personal Information that we collected from you.
In some cases, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another person. In other cases, we may decline to honor your request where an exception applies. An exception may apply where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA, such as: Personal Information we collect about Customers as described in “What is Personal Information?” above; information relating to our employees and contractors that is used for our employment, employee benefits, and vendor management purposes; and information about beneficiaries or dependents of our employees that is used to administer employee benefits.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
How to Make Requests.
If you are a California resident, you may make the requests described above by submitting a request any time on our Online Request Portal (available 24/7) or by calling us at (844) 859-1865 (available M-F 5:30 AM – 2:30 PM Pacific, excluding observed holidays).
The right under the CCPA to make these requests does not apply to Personal Information we collect about Customers as described in “What is Personal Information?” above. As a result, that Personal Information is exempt from these requests.