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CALIFORNIA PRIVACY STATEMENT

1.     Introduction

This CALIFORNIA CONSUMER PRIVACY STATEMENT supplements the information contained in the DRiV Privacy Statement and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other applicable California privacy laws. 

 

2.     Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular household, consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

·         Personal Identifiers: Examples include your first and last name, email address, postal address, unique personal identifier, online identifier, account name, or other similar identifiers.

We obtain the categories of personal information listed above from the following sources:

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing products and services to them.
  • Directly and indirectly from activity on our website. For example, from submissions made through our web portal or website usage details collected automatically.

 

3.     How We Use Your Personal Information

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

  • To fulfill or meet the purpose for which the information is provided. For example, we may collect personal information to create an account for you.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To improve our website and present its contents to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

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.

 

4.     How We Share Your Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep the personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Identifiers such as name, postal address, unique personal identifier, email address, account name, or other similar identifiers.

We disclose your personal information for a business purpose to the following categories of recipients:

  • Our business affiliates.
  • Our service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information. We do not sell personal information.

 

5.     Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your request, we will disclose to you:

  • The sources of the personal information we collected about you.
  • The categories of personal information we collected about you.
  • 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).
  • Our business or commercial purpose for collecting that personal information.
  • 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.

Deletion Request Rights

The CCPA provides you with the right to request that we delete any of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will 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 providers to:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or take legal action against those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

6.     How to Exercise Your CCPA Rights

To exercise your right to access, data portability, and deletion as described above, please submit a request to us by:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a consumer request related to your personal information. You may also make a consumer request on behalf of your minor child.

You may only make a consumer request for access or data portability twice within a 12-month period. The 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.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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 request to verify the requestor's identity or authority to make the request.

 

7.     Response Timing, Format and Fees

We will respond to a verifiable consumer request within 45 days of receipt.  If additional time is required (up to 90 days), we will inform you of the reason and extension period in writing.  We will provide our written response by mail or email, at your request.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your 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.

 

8.     Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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

 

9.     Changes to Our Privacy Statement

We may modify or update this privacy statement from time to time. If we change this privacy statement, we will notify you of the changes by publishing an updated statement on our Site. Where changes will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have.

 

10.     Contact Information

If you have any questions or comments about this statement, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

DRiV Privacy Office  

Attention: The Privacy Officer
500 N Field Drive, Lake Forest, IL 60045, USA
Email: PrivacyOffice@DRiV.Com   

 

Effective : January 1, 2020