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California Consumer Privacy Act Disclosures

Last Updated: April 12,

This Privacy Policy for California Residents is provided by Vandeventer Black LLP, and the Vandeventer Black Foundation, Inc. (“Vandeventer Black LLP”, Vandeventer Black Foundation “we”, “our” “us”), and applies solely to the Personal Information (as defined below in Section 1) that we collect and use relating to consumers and users who reside in the State of California (“users,” “consumers” or “you”). This Privacy Policy is applicable to the publications, businesses, websites and mobile applications operated by Vandeventer Black LLP, Vandeventer Black Foundation, including the Website from which you accessed this Privacy Policy (our websites and mobile applications are collectively referred to as  “Websites”).  We provide this Privacy Policy to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (CCPA).

By using our Website and providing us with Personal Information you agree to the practices described in this Privacy Policy and our Cookie Policy and to the updates to these policies posted here from time to time. To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Last Updated” date shown above.

For purposes of this Privacy Policy, except where a different definition is noted, “Personal Information” means 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, household, or device.

Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Other information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

1. Categories of Personal Information Collected

The Personal Information we collect from consumers fall into the following categories as established by the CCPA:

  • Identifiers including:
    • Your full name or online identifier such as username
    • Your postal address
    • Your email address
    • Your internet protocol
  • Personal Information: such as your telephone number or your country of origin or
  • Professional information: such as your company name and title/position or business affiliation or job preferences
  • Records and copies of your correspondence or messages if you contact us via the Website or through any other method.
  • Internet or other electronic network activity information including your interaction with the Website (see “Information We Collect Through Automatic Data Collection Technologies”).
  • Information from any Curriculum Vitae you submit to us to apply for a position, including the Personal Information described above as well as your academic background, professional experience, and employment history, and photograph, where applicable.
  • Commercial Information: such as transaction history when you make payments via our third-party providers on our Website.

2. Categories of Personal Information Disclosed for A Business Purpose

The Personal Information we collect and disclose about consumers for a business purpose fall into the following categories established by the CCPA:

    • Identifiers such as your full name or online identifier such as username, postal address, email address, internet protocol address
    • Personal Information such as your telephone number or country of origin
    • Professional information such as your company name and title/position or business affiliation or job preferences
    • Records and copies of your correspondence or messages
    • Internet or other electronic network activity information to help us analyze our Website usage and to detect and address security incidents

We may use or disclose Personal Information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.

    • Auditing Interactions with Consumers.  For example: monitoring traffic to our Websites, counting ad impressions, and auditing legal and regulatory compliance.
    • For example, maintaining the safety, security, and integrity of our Website, products and Services, databases, and other technology assets and our business, including preventing fraud, detecting security breaches, and prosecuting violators, and responding to law enforcement requests, and meeting requirements of applicable law, court order, or governmental regulations.
    • Debugging/Repair.  For example, identifying and repairing errors in our Websites’ functionality.
    • Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
    • Performing Services. For example, creating, maintaining, customizing, and securing your account with us, processing your payments, hosting our Website, managing databases, performing analyses, and marketing services such as managing promotions and contests.
    • Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Website, and our services.
    • Quality and Safety Maintenance and Verification.  For example, improving, upgrading, or enhancing our services and our Website and verifying the quality or safety of our Websites or Services.
    • Other Commercial Purposes. For example, as described to you when collecting your Personal Information such as for promotions or contests, or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred.

If we decide to collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

In response to a verified consumer request to know what Personal Information was collected or sold, we will investigate and provide an individualized response to the consumer, which will include the business or commercial purpose for collecting and/or sharing that information. We will not merely refer the consumer to our general practices outlined in this Privacy Policy unless our response would be the same for all consumers and this Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

3. Right to Request Access to or Deletion of Personal Information

The CCPA gives California residents the following privacy rights:

    • The Right To Know
    • The Right to Delete
    • The Right to Opt-Out of Sales of Personal Information
    • Non-discrimination

Under the CCPA, you have the right to request information about the collection or sharing of your personal information by us or access to, or deletion (under certain circumstances), of your Personal Information.  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, including if we need the Personal Information for a reason related to our business, such as:

(1) providing goods or Services to you;
(2) detecting and resolving issues related to security or functionality;
(3) complying with legal obligations;
(4) conducting research in the public interest;
(5) exercising free speech or ensuring another’s exercise of free speech; or
(6) using the information for internal purposes that a consumer might reasonably expect.

If you wish to exercise these rights, please contact us by clicking here to receive information on how to submit your verifiable consumer request.  After we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records within the time period required by the CCPA, unless an exception applies.

4. No Sale of Personal Information

Although we do not sell your personal information for money, we may share information with third-party providers in exchange for their support in enhancing your experiences with us, keeping you aware of our services, or improving our ability to serve you.  Such disclosures may be considered sales under certain laws thus, we may have “sold” (as that term is defined in the CCPA) Personal Information in the following categories listed below from consumers within the last twelve (12) months. Please note that the CCPA uses an expanded definition of the term, in which “sell” means:

“Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer’s personal information with a third party, whether for valuable consideration or for no consideration, for the third party’s commercial purposes.”

When we disclose that we may have sold Personal Information, it means that we may have received some kind of benefit to our company in return for sharing Personal Information, but not necessarily received any money in exchange.

The categories below are those defined in the CCPA.  This does not mean that all examples of that category of Personal Information were in fact “sold” but reflects our good-faith belief to the best of our knowledge that some of that information may have been shared for value in return. We will update this disclosure from time to time as appropriate.

In response to a verified consumer request for categories of Personal Information “sold,” we will investigate and provide an individualized response to the consumer, and will not merely refer the consumer to our general practices outlined in this Privacy Policy unless our response would be the same for all consumers and this Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

Category

A. Identifiers.
B. Personal information categories listed in the California Customer Records statute.
C. Protected classification characteristics under California or federal law.
D. Commercial information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
J. Non-public education information.
K. Inferences drawn from other personal information.

4.1 Do Not Sell My Personal Information

Right to Know about Personal Information Collected or “Sold”

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. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:

    • 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 or selling 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 sold your Personal Information, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
      (i) sales, identifying the Personal Information categories that each category of recipient purchased; and
      (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

The following link:  Do Not Sell My Personal Information will provide you with information to exercise your options.

5. Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us through the web form link provided in this Policy.

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, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information in question.

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.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

5.1 Response Timing and Format

We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing. We will deliver our written response by email if you provided it, or by postal mail if that is the only method of communication you have provided.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. For data portability requests, we will select a commercially reasonable format to provide your Personal Information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media. 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.

6. No Discrimination

We will not discriminate against any consumer for exercising their rights under the CCPA.  In particular, we will not:

    • Deny you goods or services.
    • Charge you different prices for goods or services, whether through denying benefits or imposing penalties.
    • Provide you with a different level or quality of goods or services.
    • Threaten you with any of the above.
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