California Privacy Notice
1. Information We Collect
We collect 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 or household (“personal information”). Personal Information may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope.
In particular, within the last 12 months we have collected the following categories of personal information from the sources and for the business or commercial purposes described below:
Description of Category
What We Collect
Business or Commercial Purposes for Collection
A real name, postal address, online identifier, internet protocol address, email address, or other similar identifiers.
Providing our Services; sending communications; analyzing trends; enhancing our Services.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (Customer Records Data).
A name, address, telephone number, employment, or any other financial information. *Some personal information included in this category may overlap with other categories.
Directly from the consumer.
Providing our Services; sending communications; analyzing trends; enhancing our Services.
Internet or other similar network activity (Internet Use Data).
Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.
Enhancing Services; analyzing trends.
2. Use of Personal Information
In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:
To process your requests and transactions and to prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To create, maintain, customize, and secure your account with us.
For testing, research, analysis, and product development, including to develop and improve the Services and our products.
To provide, support, personalize, and develop the Services and our products.
To help maintain the safety, security, and integrity of the Services and our products, databases, other technology assets, and business.
To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Services, third-party sites, and via email or text message (with your consent, where required by law).
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, equity or a similar transaction, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of the Services is among the assets transferred.
As otherwise described to you when collecting your personal information.
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.
3. Sharing Personal Information
We share your personal information for a business purpose to the following categories of third parties:
· Service providers.
· Cloud service providers.
· Operating systems and platforms.
When we disclose your personal information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your personal information is disclosed and restricts the service provider from using your personal information for any purpose except performing the contract.
In the preceding 12 months, we have disclosed to these third parties the following categories of personal information for a business purpose:
· Identity Data.
· Customer Records Data.
· Commercial Data.
Sales of Personal Information
We do not sell your personal information, as defined by the CCPA, to third parties.
4. Your Rights and Choices
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 (see Exercising Access, Data Portability, and Deletion Rights), 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 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 disclosed for a business purpose, a list 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 (see Exercising Access, Data Portability, and Deletion Rights), 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:
- Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty conducted in accordance with federal law, 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.
- 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 that consumer’s free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. 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 the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized 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.
- 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. We may require authentication of the consumer that is reasonable in light of the nature of the personal information requested. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 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. If no preference is specified we will delivery our response electronically.
Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer 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 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 the request 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. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
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, including denial 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.
6. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services 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 send an email to us.
7. Changes to this Privacy Notice
We reserve the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on the Services and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing the Services and this privacy notice to check for any updates or changes. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.
8. Contact Us
If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please call us at (303) 295-0777, email us at firstname.lastname@example.org, or write to us at Public Trust Advisors, LLC Compliance Department 717 17th Street, Suite 1850 Denver, CO 80202.
Public Trust maintains safeguards to comply with federal and state standards to guard each client’s nonpublic information. We do not share any nonpublic information with any nonaffiliated third parties except in the following circumstances:
As necessary to provide the service that the client has requested or authorized or to maintain and service the client’s account; and
As required by regulatory authorities or law enforcement officials who have jurisdiction over the investment adviser or as otherwise required by any applicable state open records law; and
To the extent reasonably necessary to prevent fraud and unauthorized transactions.