This notice describes our collection, use and disclosure of personal information of California residents in our capacity as a "business" under the California Consumer Privacy Act ("CCPA") and their rights with respect to their personal information. For purposes of this California privacy notice, "personal information" has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA, such as information described in our Privacy Policy pursuant to the Gramm-Leach-Bliley Act.
Your privacy rights. If you’re a California resident, you have the following rights under the CCPA:
Right to know. You can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared or disclosed for a business purpose.
Right to access. You can request a copy of certain personal information that we have collected about you.
Right to deletion. You can request that we delete personal information that we collected from you.
Right to correction. You can request that we correct inaccurate personal information that we have collected about you.
Right to opt-out. You can request to opt-out of disclosures of your personal information that constitute "selling" or "sharing" of your personal information as defined in the CCPA.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
You may submit requests to exercise your right to know, access, deletion and correction by emailing [email protected]. The rights described above are not absolute, and in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into your account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address or telephone number used to make the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
Sales and sharing of personal information. Our use of the interest based advertising services described above may constitute "sharing" of your personal information under the CCPA from which you have the right to opt-out. That is because these services use our users' personal information (specifically, the contact data, device data and online activity data described above in Personal Information We Collect) to show you ads they think may interest you on other online services. You may opt-out of such sharing by Strategic Consulting by clicking 'Your Privacy Choices' at the footer of this site. Your request to opt-out will apply only to the browser and the device from which you submit the request. We do not "sell" personal information as defined by the CCPA, and have no actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
Deidentified data. We do not to attempt to reidentify deidentified information that we derive from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described in the Privacy Policy.
Collection and disclosure. The chart below describes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose it. The terms in the chart refer to the categories of information and third parties detailed above in the Personal Information We Collect section. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to professional advisors, law enforcement and government authorities, and business transferees as described above in the How We Share Your Personal Information section of this Privacy Policy.
| Statutory category Personal information we collect |
Categories of third parties to whom we disclose the personal information for a business purpose |
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