As of July 30, 2021
The Information We Collect
We collect information that identifies, relates to, describes, or could be reasonably linked, directly or indirectly, with a particular consumer.
Information we may have collected within the last 12 months includes:
a. Identifiers – name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account number, Social Security number, driver’s license number, government identification number, passport number, or other similar identifiers.
b. Other personal information – name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bankruptcy status, bank account number, credit card number, debit card number, or any other financial information, or medical information. Some personal information included in this category may overlap with other categories.
c. 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).
d. Commercial information – Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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, or gait.
f. Internet or other similar network activity– Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
g. Geolocation data – physical location or movements.
h. Sensory data – Audio, electronic, visual, thermal, olfactory, or similar information.
i. Professional or employment-related information – Current or past job history or performance evaluations.
j. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 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.
k. Inferences drawn from other personal information – Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
How We Use Your Personal Information
a. To fulfill or meet the reason you provided the information
b. To create, support, update, and develop our services and marketing efforts
c. To create and maintain a relationship with you or provide services
d. To provide you with information that you request from us
e. To carry out any obligations we have and enforce our rights in contracts agreed upon, including for billing and collections
f. For testing, research, and analysis of our marketing
g. To respond to law enforcement requests as required and applicable by law, court order, or government regulation
h. To evaluate or conduct merger and acquisition activity
i. For quality control of our services
Sharing Personal Information
We may disclose your personal information to a third party only for relevant business purposes. This information is not used with the third party except for the sole reason(s) as outlined in our contract with the third party.
Collection of Personal Information
We have collected Personal Information from the following categories of sources: directly from you (e.g. via web submission form, forms you complete when purchase services, or job applications), directly or indirectly from someone other than you, and public records from government entities.
Sale of Information
We have not and will not sell your Personal Information.
Your Rights and Choices
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.
You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the last 12 months. Upon receiving and verifying your request we will disclose to you:
a. The categories of information we have collected about you
b. The sources of the personal information we collected about you
c. Our purpose for collecting that information
d. The parties with which we shared the information
e. The specific pieces of information we collected about you (also known as a data portability request)
You have the right to request that we delete any of the personal information we have collected about you, subject to certain exceptions. Once we verify your request, we will have your information removed from our records as well as records of any third parties, unless an exception is required.
We may deny your request if retaining the information, we collected about you is necessary for us to:
a. Complete the transaction for which we collected the personal information, provide a 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
b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
c. Debug to identify and repair errors that impair existing intended functionality.
d. Exercise a right provided by law
e. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546)
f. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
g. Comply with a legal or regulatory obligation
h. Make other internal and lawful uses of that information that are compatible with the context in which you provided it
i. Engage in statistical or other relevant and legal research in which deletion of the personal information would make such research impossible to complete
These deletion rights do not apply to B2B personal information. We may deny your request for deletion if we are unable to verify your identity or have reason to believe the request if fraudulent.
Only your or someone who is legally authorized to act on your behalf, with proof of authorization, can make a request to know or delete your personal information.
To submit a request, email CCPA@whitleypenn.com or call 800.749.4875.
We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by law, we will not:
a. Deny you services
b. Charge you a different price for services on the basis that you exercised your rights under the CCPA
c. Provide financial incentives that will persuade you into allowing us to keep your personal information
d. Suggest that you will receive a different price for our services on the basis of exercising your rights under the CCPA
Changes to Our Policy
We reserve the right to update or amend the policy on this website at any time without prior notice. Your continued use of this website following the posting of changes constitutes your acceptance of such changes.
To submit a request, email CCPA@whitleypenn.com or call 800.749.4875.