California Consumer Privacy Act (“CCPA”) Rights

As of January 1, 2020, verified California residents have the right to:

  • request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information.
  • request and receive a copy of the personal information we have collected about them during the prior 12 months.
  • request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose.
  • request that we not sell personal information about them and
  • request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.

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.

In order to make a request for disclosure California residents may contact us by calling us toll-free at (800) 811-4880 or by visiting our CCPA Request Page HERE.  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. 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.

You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period.  You may make a request that we not sell information or for deletion of your information at any time.

For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily usable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

For requests for deletion of your information 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.

Selling Information.  We do not sell your information for monetary or any other valuable consideration.

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) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us.  We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

We will not discriminate against you as a result of your exercise of any of these rights.

During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties.  The categories of information include information we collect from our website visitors, registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals.  For instance, we may collect different information from applicants for employment or from vendors or from customers.

Category of Information collected Source Business purposes * for use Categories of third parties receiving information
Identifiers (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) Individuals submitting information to us;

information we automatically collect from site visitors.

Performing services for you;

quality control.

Service providers (such as payment processors, employee benefits partners).
Sensitive Information (name with financial account, medical, health, and health insurance information, user name and password) Individuals submitting information;

employment applications;

employees.

Performing services for you. Service providers (such as payment processors, employee benefits partners)
Protected classification information (race, gender, ethnicity, religion) Individuals submitting information. Performing services for you. Service providers (such as employee benefits partners).
Commercial information (transaction history, products/services purchased, obtained or considered, product preference) Individuals submitting information to us;

information we collect from visitors.

performing services to you;

internal research and development;

quality control.

Not Shared
Electronic network activity (browsing or search history, website interactions, advertisement interactions) Not Collected N/A N/A
Audio, video or similar information (customer service calls, security monitoring) Individuals submitting information;

information we collect for security purposes.

Security detection, protection and enforcement;

performing services for you.

Law enforcement (if requested)
Biometrics Not Collected N/A N/A
Geolocation Information we automatically collect from site visitors. Performing services for you; Service provider (such as web administrator).
Professional, educational or employment related information Information submitted by individuals;

information received from third parties in connection with vendor or employment status or applications;

information we observe in connection with vendor or employment oversight.

Performing services for you. Service providers (such as payment processors, employee benefits partners);

government regulators;

law enforcement.

Inference from the above (preferences, characteristics, behavior, attitudes, abilities, etc.) N/A N/A N/A

*More specifically, the business purposes include:

  1. Performing services for you:
  • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
  • To respond to queries or requests and to provide services and support;
  1. Security detection, protection and enforcement; functionality debugging, error repair.
  • As part of our efforts to keep our Sites safe and secure;
  • To prevent or detect fraud, malicious activity or abuses of our Sites, for example, by requesting verification information in order to reset your account password (if applicable);
  • To ensure the physical security of our premises through the monitoring of

surveillance images;

  • To resolve disputes, to protect the rights, safety and interests ourselves, our users or others, and to comply with our legal obligations.
  1. Quality control.
  • To monitor quality control and ensure compliance with our legal obligations, codes and ordinances, policies and procedures,
  • To develop and improve our products and services, for example, by reviewing visits to the Sites and various subpages, demand for specific products and services and user comments.