Privacy Notice for California Residents

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

• A real name, internet protocol address, email address, or other similar identifiers

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

Commercial Information

• Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Internet or Other Electronic Network Activity Information

• Browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application or advertisement

Inferences drawn from other Personal Information

• Profile reflecting an individual’s preferences, characteristics, predispositions

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our Website for products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• Records and copies of your correspondence (including email addresses), if you contact us in relation to our products or services.
• Your responses to surveys that we might ask you to complete for research or marketing purposes.
• Details of transactions you carry out on our Website, and fulfillment of your service orders.

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:

• Emailing us at ccpa@bcmone.com
• Calling us at 1-646-351-0094

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”.