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Effective: January 1, 2020
Last Updated: January 1, 2020
This Privacy Policy provides additional information solely for California residents, as required under the California Consumer Privacy Act of 2018 (“CCPA”). As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information described below.
The information below applies to personal information as defined in the CCPA collected both online and offline. For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.
Personal information does not include publicly available information, information that has been de-identified, aggregated consumer information, and information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure. Some personal information included in the categories may overlap with other categories.
| Category | Examples | Collected | Disclosed for a business purpose(s) |
|---|---|---|---|
| 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 | YES |
| B. Personal information categories as described 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. | YES | YES |
| C. Characteristics of protected classifications under California law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex/gender (includes pregnancy, childbirth, breastfeeding and/ or related medical conditions), gender identity, gender expression, sexual orientation, genetic information, and veteran or military status. | YES | YES |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES | 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 for customers YES for certain employees |
NO for customers YES for certain employees |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | YES | YES |
| G. Geolocation Data | Physical location or movements. | YES | YES |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information, including call recordings and photographs. | YES | YES |
| I. Professional or Employment-Related Information | Current or past employment history, qualifications, licensing, and disciplinary record. | YES | YES |
| J. Non-Public Education information | Education records directly related to a student maintained by an educational agency or institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes and student disciplinary records. | NO | 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 | YES |
We may collect the categories of personal information listed above from the following categories of sources:
We may use or disclose the personal information we collect for one or more of the following “business purposes” or “commercial purposes” (as defined in the CCPA):
We may disclose personal information to the following categories of third parties for a “business purpose” or “commercial purpose” (as defined in the CCPA):
In the past 12 months, we have not “sold” personal information subject to the CCPA, including personal information of minors under the age of 16. For purposes of this Notice, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration. As noted elsewhere in this Notice, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information. However, we support consumer choice regarding use of consumers’ personal information and for this reason, refer you to the “Right to Opt-out of Sales” section immediately below for more information on how to register your choice with us with regard to future uses of your personal information.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights under the CCPA and explains how to exercise those rights. Subject to certain exceptions, California consumers have the right to make the following requests:
Right to Opt-out of Sales: We are not selling personal information of California residents. Further, we will not sell personal information if we have actual knowledge that the consumer is less than 16 years of age, unless we receive affirmative authorization (“opt-in”) from either the consumer between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
If you would like to register your choice with regard to future uses of your personal information, please visit our CCPA Request form by clicking here, and we will register your details for this purpose.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:
Right to Access: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:
Right to Delete: You have the right to request that we delete and direct any service providers that have received that personal information to delete, the personal information that we have collected and retained, subject to certain exceptions, including if we need the personal information for a reason related to our business, such as:
Once we receive and confirm your verifiable request, we will delete (and, if applicable, direct our service providers to delete) your personal information from our records, unless an exemption applies.
Submitting Requests: You can submit an access request and/or deletion request by either:
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Response Timing and Format: We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.
We will deliver our written response by email if one is attached to your account with us. If no email is on file, we will deliver our written response by first class mail to the mailing address attached to your account with us.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights or impose unreasonable requirements on financial incentives offered to California consumers related to your personal information. We may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of your personal information.
This Notice may change at any time and from time to time to reflect changing legal, regulatory or operational requirements. If we make material changes, we will post the updated notice on this page and change the “Last Revised” date at the top. Any amendments or modifications to this Notice will become effective immediately upon posting. Your continued use of any of Our Services following the posting of an updated version of this Notice will constitute your acceptance of the updated Notice. If you do not agree with the revised Notice, please discontinue use of any of Our Services.
As a California resident, you have certain rights, subject to legal limitations, regarding the collection, use, and sharing of your personal information under the California Consumer Privacy Act (“CCPA”) as described in our Privacy Policies and the California Privacy Notice.
If you would like to submit a request under the CCPA, please complete and submit the form below.
Please note that while we will comply with any applicable obligations under the CCPA, we may not have an obligation to, or may not be able to, honor your request.