Privacy Notice for California Residents
Privacy Notice for California Residents
Effective Date: January 1, 2020
Last Updated: October 6, 2020
This Privacy Notice for California Residents (this “Notice”) is provided by Proskauer Rose LLP (USA) a New York registered limited liability partnership with registered affiliated offices in the USA, France, Hong Kong and China, Proskauer Rose (UK) LLP (UK), an English registered limited liability partnership, and Proskauer Rose Brazil – Consultores em Direito Estrangeiro/Direito Norte-Americano e Direito Ingles, a Brazilian partnership (collectively, “Proskauer”, “we”, “our” and similar pronouns). Please note the following:
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”). Personal information does not include:
In particular, we have collected the following categories of personal information from consumers within the preceding twelve (12) months:
We obtain the categories of personal information listed above from the following categories of sources:
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business or commercial purpose:
In the preceding 12 months, we have shared the categories of personal information listed above for business purposes with our service providers and business partners who assist in providing our services or operating our business.
The definition of “sale” in the CCPA includes more activities than we typically consider to be a “sale” of personal information. In the past 12 months, we have not sold Personal Information and we will not sell Personal Information in the future, as we understand the term “sell” based on the CCPA and its implementing regulations.
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, which are subject to our records retention policies and applicable law.
Where noted, these rights do not apply to (i) personal information collected about employees, job applicants, contractors or similar individuals and used only within the context of such a relationship (“employment-related personal information”) or (ii) personal information reflecting a written or verbal business-to-business communication (“B2B personal information”).
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose the following information to you with respect to the preceding 12 months:
These access and data portability rights do not apply to employment-related personal information or B2B personal information, for so long as an exception under the CCPA applies to such information.
Deletion Request Rights
You have the right to request that we delete the personal information (other than employment-related personal information or B2B personal information) we collected about you, subject to certain exceptions provided by the CCPA. Once we receive and confirm your verifiable consumer request, we will delete the requested personal information from our records, unless an exception provided by the CCPA applies. For example, we may retain personal information as required or permitted by law, and may maintain a copy of your deletion request.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
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. 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. Please describe your request with sufficient detail for us to properly understand, evaluate and respond to it.
Personal Information Sales Opt-Out and Opt-In Rights
You have the right to opt out of our future “sale” of your personal information. To do so, you may submit a do-not-sell request by:
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from the consumer who is at least 13, but not yet 16, years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to personal information sales may opt out of future sales at any time.
Requests from Authorized Agents
If you would like an authorized agent to submit a CCPA request on your behalf or if you are an authorized agent of a consumer and registered with the Secretary of State to conduct business in California, please send us an email at firstname.lastname@example.org for instructions and details on proof required for use of an authorized agent, including a copy of the written permission signed by the consumer for the agent to act on the consumer’s behalf in this manner.
You have a right under the CCPA not to receive discriminatory treatment by us because you exercised any of your CCPA rights.
Persons with disabilities may obtain this Notice in an alternative format upon request by contacting us at email@example.com
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated notice on the Proskauer Sites and update the notice’s effective date. Your continued use of the Proskauer Sites following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address: 640 8th Avenue, New York, New York 10036