Privacy Statement – California Residents

This PRIVACY NOTICE IS APPLICABLE TO CALIFORNIA RESIDENTS (“consumers” or “you”) ONLY. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”), and other California privacy laws. Any terms defined in the CCPA or CPRA have the same meaning when used in this notice.

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 consumer or device (“Personal Information”).

We have collected the following categories of Personal Information from California consumers since January 1, 2020:

  Category Examples
A. Identifiers. Account Name, Address, Beneficiary Name, Beneficiary Relationship, Client ID Number, Client Reference Number, Contract Number, Date of Birth, Date of Death, Driver’s License Number, Email Address, Emergency Contact Name, Emergency Contact Number, Employee Identification Number, Name, Passport Number, Phone Number, Policy Number, Policy Rating Information
B. 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
C. Characteristics of protected classifications under California or federal law. Gender, Age, Citizenship Status, Disability, Marital Status
D. Commercial Information Transaction information, purchase history, financial details, and payment information
E. Professional or employment-related information.

 

Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.

F. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Student records and directory information.
G. Inferences drawn from other personal information. Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

 

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

  • Directly from our employees and 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 services to them.
  • From third-parties that interact with us in connection with the services we perform.
  • From job applicants through 3rd party career sites.

Personal Information does NOT include:

  • Information that is lawfully made available from federal, state, or local government records (“Publicly Available Information”).
  • De-identified or aggregate consumer information (as such terms are defined in the CCPA).
  • 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.

Sensitive personal information means Information that reveals:

  • Your social security, driver’s license, or passport number.
  • Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to the account.
  • Your precise geolocation.
  • Your racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • Contents of your mail, email, and text messages unless Horace Mann is the intended recipient of your communication.
  • Your genetic data.

Unless the information is publicly available, sensitive personal information also includes:

  • Processing of biometric information for the purpose of uniquely identifying you.
  • Personal information collected and analyzed concerning your health.
  • Personal information collected and analyzed concerning your sex life or sexual orientation.

Use of 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 reason for which the information is provided.
  • To provide you with information or services.
  • To provide you with email alerts, event registrations and other notices concerning our services, or events or news, 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, including for billing and collections.
  • As reasonably necessary and proportionate to protect the rights, property or safety of us, our clients or others.
  • To respond to regulatory and/or 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.
  • As otherwise required or permitted by law

We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosing Personal Information

We may disclose your Personal Information to a third party for a business purpose.

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

Category A:    Identifiers.
Category B:    California Customer Records personal information categories.
Category C:    Protected classification characteristics under California or federal law.
Category D:    Commercial Information.

Category E:   Professional or employment-related information.
Category F:    Professional or employment-related information.
Category G:    Inferences drawn from Personal Information

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service Providers and Vendors.
  • Third parties to whom you authorize us to disclose your personal information in connection with products or services we provide to you.
  • To other third parties as required or permitted by law.

Selling or Sharing Personal Information

We do not “sell” or “share” your personal Information to anyone as those terms are defined in the CCPA.

Sensitive Personal Information

We use your Sensitive Personal Information only to perform the services reasonably expected. We may also use your Sensitive Personal Information to ensure the security and integrity of your Personal Information, perform services on behalf of our business, and undertake activities to improve or enhance our services.

Your Rights and Choices

The CCPA provides 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 collected on or after January 1, 2020. Once we receive and verify your request, we will disclose to you any of the following in accordance with 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 that Personal Information.
  • The categories of 3rd parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we have collected about you (also called a data portability request) – but only if specifically requested by you.
  • If we have disclosed your Personal Information for a business purpose, a list identifying:
      • The categories of personal information that we collected about you.
      • The categories of personal information that we disclosed about you  for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Correction Requests

You have the right to request that we correct personal information about you. After we receive and verify your request, we will evaluate the requested correction against information we receive from other sources. We will disclose to you the actions taken pursuant to your request.

Deletion Request Rights

You have the right to request that we delete (and direct our Service Providers to delete) your Personal Information from our records. Subject to the exceptions set forth below, we will comply with your deletion request and will direct our Service Providers to delete your Personal Information.

Deletion Request Exceptions

We (or our Service Providers) do not have to comply with your deletion request with regard to your Personal Information that we (or our Service Provider) maintain if it is reasonably necessary for any of the following reasons:

  1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by you within the context of a business’ ongoing business relationship with you, or otherwise perform a contract between the business and you.
  2. Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
  7. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the business and compatible with the context in which you provided the information.
  8. Comply with a legal obligation.

Exercising Access/Data Portability, Correction, and Deletion Rights

To exercise the access, data portability, correction, opt-out, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us toll-free at 469-294-5344.
  • Visiting California Resident Privacy Request page
  • Emailing request@goodmancommunication.com

Only you or a person registered with the California Secretary of State for which you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

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 your identity or your authority to make a request on behalf of a California resident.
  • 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.  Personal Information provided will only be used by us to verify the requestor’s identity and/or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  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.

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.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • 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.
  • Retaliate against an employee, applicant for employment, or independent contractor.

CalOPPA

No 3rd parties collect personally identifiable information from us about your online activities over time and across different Web sites when a consumer uses our websites.

Changes 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 notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, 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 do not hesitate to contact us at:

Phone: 469-294-5344
Email: request@goodmancommunication.com
Postal Address: Greater Tech Holdings, Inc. 103 Industrial Loop Suite 900, Fredericksburg TX 78624