Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of
sources:
- Directly from our clients or their agents. For example, from documents that our clients provide
to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from
our clients in the course of providing services to them.
- Directly and indirectly from activity on our websites (www.ClientConsent.org) and our
partner websites (as identified by the ClientConsent.org). For example, from
submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For
example, from credit bureaus such as TransUnion or Experian when you request to view your credit
report.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following
business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide
us with personal information in order for us to help you review mortgage quotes, we will use
that information to deliver quotes to you from our participating lenders.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products
or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For marketing analytics, testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or
others.
- To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the
CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal information held by us is
among the assets transferred.
We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you
notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the purpose
and requires the recipient to both keep that personal information confidential and not use it for
any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal
information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information
categories.
Category C: Protected classification characteristics under California or federal
law.
Category D: Commercial information.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third
parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in
connection with products or services we provide to you.
In the preceding twelve (12) months, we have sold personal information.
The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those
rights.
Access to Specific Information and Data Portability Rights
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 consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data
portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists
disclosing:
-
sales, identifying the personal information categories that each category of recipient
purchased; and
- disclosures for a business purpose, identifying the personal information categories that
each category of recipient obtained.
You have the right to request that we delete any of your personal information that we collected from
you and retained, subject to certain exceptions. Once we receive and confirm your verifiable
consumer request, we will delete (and direct our service providers to delete) your personal
information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service
providers to:
1. Complete the transaction for which we collected the personal information, provide a good
or
service that you requested, take actions reasonably anticipated within the context of our ongoing
business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended
functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546
seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the
public
interest that adheres to all other applicable ethics and privacy laws, when the information's
deletion may likely render impossible or seriously impair the research's achievement, if you
previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based
on
your relationship with us.
8. Comply with a legal, regulatory or contractual obligation.
9. Make other internal and lawful uses of that information that are compatible with the
context in
which you provided it.
Exercising Access, Data Portability, and Deletion Rights
Only you or a person registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your personal information. You may
also make a verifiable consumer request on behalf of your minor child.
- Provide sufficient information that allows us to reasonably verify you are the person about whom
we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate,
and respond to it.
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.
Making a verifiable consumer request does not require you to create an account with us. We will only
use personal information provided in a verifiable consumer request to verify the requestor's
identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we
require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not
have an account with us, we will deliver our written response by mail or electronically, at your
option. Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer request's receipt. The response we provide will also explain the reasons we cannot comply
with a request, if applicable. For data portability requests, we will select a format to provide
your personal information that is readily useable and should allow you to transmit the information
from one entity to another entity without hindrance.
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
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 granting discounts
or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make
changes to this privacy notice, we will notify you by email or through a notice on our website
homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which
we collect and use your personal information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to contact us at: customercare@clientconsent.org