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Privacy Notice for California Residents

 

Effective Date: January 1, 2020

Last Reviewed on: January 1, 2020

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in Randall-Reilly, LLC’s (referred to herein as “Company” or “us” or “we”) Privacy Policy and applies solely to those visitors, users, and others of the Website whom reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

 

Personal Information We Collect about California Consumers

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, household, or device (“personal information“).

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers such as name, physical address, email address, username, password and other credentials used to access Company’s products and services, social media handles, and, when you visit the Website, use our apps or interact with Company related tools, widgets or plug-ins, Internet Protocol address unique device identifier.
  • The following categories of personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” (2) signature, (3) telephone number, (4) payment information (including payment card details or online payment services number and invoicing address) and financial information (such as bank account numbers), (5) employment information for completion of job applications and related services, (6) medical information related to the employment application process, (7) driver’s license number, commercial driver’s license number and other information related to the employment application process, and (8) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in the Privacy Policy.
  • Protected classification characteristics under California or Federal law, including date of birth, gender and veteran or military status.
  • Commercial information, including (1) records of services purchased or received from Company, (2) information on or related to actions taken on the Website or mobile apps, which may include information about services considered, and/or validation or authentication of same, and (3) information about consumer preferences and behavior that we collect on the Website and mobile apps or purchase from third parties in order to target consumers for digital advertisements or to personalize content we deliver on the Website and mobile apps.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with the Website and mobile apps, and advertisements that are displayed or linked on the Website or mobile apps or our advertisements that are displayed or linked on third-party sites and apps.
  • Geolocation data.
  • Audio information from calls placed with those for whom consent had been received, or from manual dialed campaigns, which may be recorded, and electronic information in the form of Internet or other electronic network activity information as described above.
  • Professional or employment-related information in the form of business contact information such as name, company name, physical address and email address and telephone or fax number, current or past employment history, prior performance information, and other information associated with applications for employment as a commercial driver.
  • Inferences drawn from (1) the information we collect when you visit the Website, use our apps, or interact with Company related tools, widgets or plug-ins or our official social media pages or Company related social media apps, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers and vendors, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumer preferences and behavior that we collect on the Website and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, and attitudes.

We collect this information from sources including directly from you such as when you complete a form, submit an application, request a product or service, make a purchase, subscribe to a newsletter, or register for an event.  In addition, we collect information from sources such as service providers, vendors, affiliates, public databases, social media platforms, and third-party partners such as analytics or marketing providers. Furthermore, we collect information indirectly from you such as by observing your actions on the Website or on our advertisements displayed or linked on third party sites and apps.

Pursuant to the CCPA, personal information does not include the following:

 

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to subscribe to a newsletter, white paper, request product demonstration, enter a contest, register for an event, or request information regarding other products or services then we will use the personal information to fulfill such request. If you share your name and contact information to request a price quote or ask a question about a product or service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. If you provide your personal information to request a product demonstration, we will use that information to process that request. We may also save your information to facilitate new product orders, process returns, or to use such information for various marketing activities. If you provide your personal information to complete job applications, seek employment opportunities, and to complete related information requests related to seeking such prospective job opportunities then we will use that information to facilitate completion of a potential employment opportunity.
  • To provide, support, personalize, and develop the Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, applications, purchases, subscriptions, transactions, and payments and to prevent transactional fraud.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of the Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve the Website, products, and services.
  • 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 Randall-Reilly, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Randall-Reilly, LLC about the Website users is among the assets transferred.

We have disclosed name, address, telephone numbers, and email addresses of certain individuals to other businesses or third parties for monetary or other valuable consideration within the twelve (12) months preceding the effective date of this Privacy Notice. As is common practice among businesses that operate Internet Web sites, we may also have disclosed certain identifiers, information about the use of the Website and apps, and inferences drawn about you to our social media, advertising, and analytics partners for monetary or other valuable consideration.

We have disclosed personal information in all or substantially all of the categories identified in this Privacy Notice for various business purposes.

We also share personal information with third parties who perform services on our behalf. These third parties who perform services on our behalf are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may share the personal information we obtain with our affiliates, clients, and joint marketing partners. These entities, which collectively are referred to here as the “Business Partners”, may use the information for the purposes described in this Privacy Notice. We may share physical location data with our Business Partners and other third parties to, for example, enhance location-based services. In addition, except as described below, unless you object, we may share other personal information with third parties who are not Business Partners for those parties’ own purposes, such as to offer products or services that may interest you.

Information collected through third-party apps, tools, widgets and plug-ins (such as information obtained through third-party login services or relating to your use of a Facebook “Like” button) is collected directly by the providers of these features. This information is subject to the privacy policies of the providers of the features, and Company is not responsible for those providers’ information practices.

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.

 

Your Rights and Choices

The CCPA provides consumers that are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. We will honor requests received and verified to the extent required by applicable law and within the time provided by law.

  • Right to Access and Information regarding Personal Information. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
  • 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 or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We will deliver personal information that we are required by law to disclose to you in the manner required by law within 45 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the personal information to you through your account, if you maintain an account with Company, or electronically or by mail at our option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information from one entity to another. 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.

  • Right to Request Deletion of Personal Information. You have the right to request that we delete Personal Information about you that we have collected from you. Once we receive and confirm your verifiable consumer request, 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 provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or 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 their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 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 that information that are compatible with the context in which you provided it.
  • Right to Opt Out.  You have the right to opt out of the future disclosure of personal information about you for monetary or other valuable consideration.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Please note that the Website and mobile apps are not designed to support or respond to “do not track” requests from Web browsers at this time.

  • Non-Discrimination.  We will not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by:
  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

Requests to Exercise Your Rights

You may request to exercise the foregoing rights by:

  • Submitting a request by visiting Web Form
  • By submitting an email to privacy@randallreilly.com

Please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. We may limit our response to your exercise of the above rights as permitted by law.

 

Data Sharing for Direct Marketing Purposes

California Civil Code Section §1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. To make such a request please send us an email setting forth your preferences to privacy@randallreilly.com

 

Updates To Our Privacy Notice

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

 

How To Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by sending an email to privacy@randallreilly.com.

You also may write to us at: Randall-Reilly, LLC, 3200 Rice Mine Road, NE, Tuscaloosa, Alabama 35406.

Should you have a disability that prevents or limits your ability to access this policy, please email us at privacy@randallreilly.com or call us at 800.633.5953.  We will work with you to provide this notice in an alternative format.

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