Rights and Choices for California Residents |
The
California Consumer Privacy Act ("CCPA") provides California residents with
specific rights regarding their personal information. This document describes
your CCPA rights and explains how to exercise those rights.
Last
reviewed on: October 19, 2020
You
have the right to request that the Company disclose certain information to you
about our collection and use of your "personal information" over the past 12
months,
defined as
information that identifies, relates to, describes, references, is reasonably
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer, household, or device.
Personal
information does not include the following:
·
Publicly
available information that is lawfully made available to the general public
from federal, state, or local government records;
·
Deidentified
or aggregated consumer information;
·
Information
excluded from the CCPA's scope, including but not limited to:
o
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;
o
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.
Once
we receive and confirm your verifiable consumer request (see Exercising Your
Rights below), we will disclose to you, if applicable:
·
The
categories of personal information we collected about you:
o
Identifiers (e.g., real name, alias,
postal address, unique personal identifier, online identifier, internet
protocol address, email address, account name, social security number, driver's
license number);
o Other
personal information categories listed in the California Customer Records
Statute (e.g., physical characteristics or description, telephone
number, state identification card number, insurance policy number, bank account
number, credit card number, debit card number, or any other financial
information, or medical information);
o Characteristics of protected
classifications under California or federal law;
o Commercial information;
o Internet or other similar
network activity;
o Professional or
employment-related information (for employees or contractors);
o Education information (for
employees or contractors).
·
The
categories of sources for the personal information we collected about you:
o
Directly
from you when you provide information electronically, by phone, or by mail;
o Our affiliates and business partners;
o Our agents;
o Lead vendors to whom you have
provided your information;
o Client referrals;
o Users' browsers;
o Marketing vendors and
advertising networks; and
o
Social
media, if you provide us information on social media
platforms.
·
Our
business or commercial purpose for collecting, using, or selling that personal information; for
example:
o
Provide
you products and services;
o
Address
your inquiries;
o
Process
transactions;
o
Pay
agent commissions;
o
Tailor
the content and information that we may send or display to you;
o
Where
permitted, for marketing and promotional purposes, such as to provide
information to you about the products and services we offer;
o
Analyze
use of our products and services, where permitted by law;
o
Develop
new products and services;
o
Provide
and personalize our services;
o
Comply
with legal obligations;
o
Protect
our rights, property, and safety or the rights, property, and safety of others;
o
As
described to you when collecting your personal information or as otherwise set
forth in applicable law;
o
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 about our customers is among the assets
transferred.
·
The
categories of third parties with whom we share that personal information:
o
Our
affiliates and business partners;
o
Our
agents;
o
Lead
buyers;
o
Service
providers;
o
Insurance
carriers:
o
Marketing
vendors and advertising networks; and
·
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:
o Disclosures
for a business purpose, identifying the personal information categories and
specific information that each category of third-party recipient obtained.
You
have the right to request that the Company delete any of your personal
information that we collected from you and retained, subject to certain
exceptions. For example, the Company is not required to delete
your personal information if it is necessary for the Company to maintain your
personal information in order to:
·
Complete
the transaction for which the personal information was collected, provide a
good or service requested by you, or reasonably anticipated within the context
of the Company's ongoing business relationship with you, complete the payment
of agent commissions, or otherwise perform a contract between the Company and you;
·
Detect
security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity; or prosecute those responsible for that activity;
·
Debug
to identify and repair errors that impair existing intended functionality;
·
To
enable solely internal uses that are reasonably aligned with your expectations
based on your relationship with the Company;
·
Comply
with a legal obligation;
·
Otherwise
use your personal information, internally, in a lawful manner that is
compatible with the context in which you provided the information.
Once
we receive and confirm your verifiable consumer request (see Exercising Your
Rights below), we will delete (and direct our service providers to delete) your
personal information from our records, unless an exception applies under the
CCPA.
As noted above, we may "sell" your personal
information, as that term is broadly defined under the CCPA. You have the right
to request that we not sell your personal information to third parties
("opt-out")
by contacting us at
the toll-free number or website listed below.
We do
not sell the personal information of consumers we actually know are less than
16 years of age. If you are 16 years of age or older, you have the right to
direct us to not sell your personal information at any time. You may exercise
this right by contacting us as described below.
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.
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;
and
·
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.
·
Website:
To exercise any of these rights, you may submit a request to us by visiting the
following webpage Access
Capital Group, LLC Privacy Portal.
We
endeavor to respond to a verifiable consumer request within 45 days of its
receipt. If we require more time, we will inform you of the reason and
extension period in writing. 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.
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.
We will
not discriminate against you for exercising any of your CCPA rights. If you
make a CCPA request, we will not, as a direct result:
·
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; 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.
California's
"Shine the Light" law (Civil Code Section § 1798.83) permits users of
our website that are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes.
To
make such a request, please contact us using the contact methods below.
If
you have any questions or comments about your rights under California law, or
want to exercise any of these rights, please do not hesitate to contact us at:
Phone: 1-888-914-9661 and use PIN 378314