CCPA Privacy notice

California Consumer Privacy Act (CCPA)

This privacy notice (“CCPA Privacy Notice”) for California residents (hereinafter, “Consumer” or “you”) supplements the information contained in our Privacy Policy and applies solely to each Consumer.  If you are an employee, job applicant, or contractor, please refer to the CCPA Notice to Employees, Job Applicants & Contractors.  This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act (“CCPA”).  Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Notice.

Definition Specific to this CCPA Privacy Notice:

“Personal Information” under the CCPA means 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 obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you.

1. Information We Collect About You.

Our website has collected the following categories of Personal Information from Consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A 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, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	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.	YES
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 other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
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.	NO
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

2. List Consumer Rights.

You have the right under the CCPA to exercise:

a. Disclosure of Personal Information We Collect About You

You have the right to know:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information, if any; and
• The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

• Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that Personal Information about you is not retained; or
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information.

b. Disclosure of Personal Information Sold or Used for a Business Purpose

• In connection with any Personal Information we may disclose to a third party for a business purpose, you have the right to know the categories of Personal Information that we disclosed about you for a business purpose.
• In the preceding twelve (12) months, we have not sold any Personal Information.

c. Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your Personal Information from our records; and
• Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary 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 our ongoing business relationship with you, or otherwise perform a contract between you and us;
• 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;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• 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 our deletion of the Personal Information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the Personal Information.

d. Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to you by your Personal Information.

3. How to Exercise Consumer Rights and Responding Time.

If you would like to exercise any of your rights as described in this CCPA Privacy Notice, please:

• Call us, toll-free, at 470-881-8989;
• E-mail us at privacy@vantiva.com

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.

Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.

4. Verifying Your Identity

If you choose to contact us directly by email, phone or in writing, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the Personal Information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

5. Sharing Personal Information 

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

• Our subsidiaries and affiliates.
• Service providers.
• Third parties to whom you authorize us to disclose your Personal Information in connection with products or services we provide to you.

We may disclose your Personal Information to a third-party for the following purpose: 

• Auditing interactions with consumers  
• Security  
• Debugging/repair  
• Certain short-term uses  
• Performing services  
• Quality and safety maintenance and verification

6. Changes to Our CCPA Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at our discretion and at any time. When we make changes to this CCPA Privacy Notice, we will post the updated CCPA Privacy Notice on the Website and update the its effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

• Effective date: January 1, 2020
• Last review: March 13th, 2024