This Privacy Notice for California residents supplements the information contained in the BCM One Privacy Policy and applies solely to individuals residing in California from whom we collect Personal Information (“California Consumers”). 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 notice. To the extent of any conflict between this CCPA Policy and the rest of our Privacy Policy, this Privacy Notice for California residents shall control only with respect to California consumers and their Personal Information.
Information We Collect
The below outlines the categories of Personal Information (which are defined by the CCPA, not us) that we have collected and/or disclosed for a business purpose in the preceding twelve (12) months. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect or disclose, and more information about our specific practices can be found in our Privacy Policy:
Categories & Examples (not intended to be exhaustive):
Identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Commercial Information
Internet or Other Electronic Network Activity Information
Inferences drawn from other Personal Information
We obtain the categories of Personal Information listed above from the following categories of sources:
Collection and Disclosure of Personal Information
The CCPA defines various business and commercial purposes for collecting, using and disclosing Personal Information. We collect, use and disclose California Consumers’ Personal Information pursuant to our Privacy Policy as a whole.
As also explained in our Privacy Policy, we share your Personal Information with the following categories of CCPA third parties: vendors and service providers, including for data analytics and marketing and advertising our products and services to you; third parties integrated into our services; third parties as required by law and similar disclosures; third parties in connection with a merger, sale, or asset transfer; and, other third parties for whom we have obtained your permission to disclose your Personal Information.
Access
California consumers may request access to the Personal Information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months, upon appropriate verification. California consumers may only make such requests twice (2) per every twelve (12) months.
Deletion
California Consumers have the right to request that we delete Personal Information collected and maintained about them, subject to certain exceptions. Once a California Consumer’s request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your Personal Information accordingly. A California Consumer’s request to delete Personal Information may be denied if it is necessary for us to retain the information under one or more of the exceptions listed in the CCPA. Please note that a record of the deletion request may be kept pursuant to our legal obligations.
Exercising These Rights
To exercise the access and deletion rights described above, please submit a request to us by either:
Please note that California consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.
Verifying the Request
Only the California consumer, or a person that is authorized to act on their behalf, may make a request related to the California consumer’s Personal Information. In the case of access and deletion, the request must be verifiable before we can fulfill such request.
Verifying a request will require sufficient information for us to reasonably verify that the California consumer is the person about whom we collected Personal Information, or a person authorized to act on their behalf (e.g., previous transactions of person to whom request relates).
Please note that we may charge a reasonable fee, or refuse to act on a request, if such request is excessive, repetitive, or manifestly unfounded.
“Shine the Light” Law
We do not rent, sell, or share your Personal Information with non-affiliated companies for their direct marketing purposes, unless we have your permission.
Contact Information
If you have any questions regarding our privacy practices as it relates to this Privacy Notice for California Residents, please contact us via email at ccpa@bcmone.com with the subject line, “CCPA Policy”.