PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The following applies to you only if you are a California resident.

  • Users can visit our website anonymously without providing their Personal Information, but we may collect some Personal Information, such as IP addresses, automatically through the use of cookies or other tracking technologies;
  • We will add a link to this Privacy Notice on our home page, or at a minimum, on the first significant page after entering the website;
  • Our Privacy Policy link includes the word “Privacy” and can be easily be found on the page specified above;
  • Users will be notified of any privacy policy changes on our Privacy Policy page;
  • Users are able to change their Personal Information by emailing us or by calling us;
  • Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we do not process or respond to such signals in users’ web browsers at this time; and
  • We allow the collection of users’ behavioral tracking by third parties, this may include the collection of IP addresses, which may be Personal Information.

Your Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides consumers who are California residents with specific rights regarding their Personal Information.

Right to Know About Personal Information Collected, Disclosed, or Sold

As a California consumer, you have a right to request what Personal Information we have collected, used, disclosed, and sold over the past 12 months. Once we receive and confirm your verifiable consumer request as described below, we will disclose to you:

  • The categories of Personal Information we collected about you
  • The categories of the sources for the Personal Information we collected about you
  • Our business and/or commercial purpose(s) for collecting or selling that Personal Information
  • The categories of third parties with whom we shared that Personal Information
  • The specific pieces of Personal information we collected about you

Right to Request Deletion of Personal Information

As a California consumer, you have the right to request that we delete any or all 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 to delete your Personal Information if retaining the Personal Information is necessary for us or our service providers to:

  • 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
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
  • Debug products to identify and repair errors that impair existing intended functionality
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
  • 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
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
  • Comply with a legal obligation
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it

Right to Opt-Out of the Sale of Personal Information

As a California consumer, you have the right to opt-out of the sale of your Personal Information. We do not sell Personal Information as we understand that term under the CCPA.

Right to Non-Discrimination if You Exercise any of Your Rights

As a California consumer, you have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services.
  • 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.

How to Exercise Your Rights to Know and to Delete

To exercise your rights to know and/or to delete described above, please submit a verifiable consumer request to us by:

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 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 your 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 your 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 will confirm receipt of your verifiable consumer request within ten (10) days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. 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. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. 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 useable and should allow you to transmit the information from one entity to another entity.

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.

Information We Collect From California Consumers

We collect Personal Information that identifies, relates to, describes, references, is 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:

  • Publicly available information that is lawfully made from federal, state, or local government records
  • Deidentified or aggregated consumer information
  • Medical information or protected health information governed by California and federal health information privacy laws
  • Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)
  • Personal information regulated by the Fair Credit Reporting Act (FCRA)

Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other:

Category of Personal Information Examples Collected
A. Identifiers A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number YES
B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e)) All of the Identifiers listed above, plus:

Signature, social security number, physical characteristics or description, 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

 NO
C. Legally Protected Characteristics Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) NO
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies NO
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
F. Internet or similar network activity Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement YES
G. Geolocation data Physical location or movements NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information NO
I. Employment information Professional or employment-related information NO
J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records NO
K. Inferences drawn of other categories of Personal Information A profile created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes NO

 

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from our Users. For example, from information that you provide to us through our online forms, email, or other means
  • Indirectly from activity on our Sites. For example, from website usage details collected automatically

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
  • To provide you with information that you request from us
  • To provide you with emails containing information 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
  • To improve our website and present the contents to you
  • For testing, research and analysis
  • As necessary or appropriate to protect the rights, property or safety of us, our user, 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 California Consumer Privacy Act (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 into 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 to third parties for a business purpose:

Category A: Identifiers.
Category F: Internet activity

In the preceding twelve (12) months, we have not disclosed Personal Information to third parties for a commercial purpose.

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Our service providers
  • Third parties to whom you authorize us to disclose your Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information as we understand that term under the CCPA.

Grievances and Complaints

Under California Civil Code Section 1789.3, residents of California who use this website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

Contact for More Information

If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at CURExxon@gagnierfc.com.

Date last updated: January 28, 2021