PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Modified: January 1, 2023
This Privacy Notice for California Residents (“Privacy Notice”) supplements any other privacy notice provided by Randall-Reilly, LLC (“Randall-Reilly,” “we,” “us,” or “our”) and applies solely to individuals who reside in the State of California (“consumers” or “you”). Terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this Privacy Notice.
Right to Know
California residents have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.
The below chart reflects the categories of personal information we have collected from California residents during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information.
Personal Information Category set forth in Cal. Civ. Code § 1798.140 | Source(s) of Personal Information Collection | Business or Commercial Purpose(s) for Collection/Use | Third Parties, Service Providers, and Contractors Receiving Personal Information Category | Retention Period |
Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license or passport number, or other similar identifiers. | Directly from you; indirectly from you as you navigate or use our website, applications, or services; advertising networks; internet service providers; data analytics providers.
For job applicants: Recruiters; background check providers. | Fulfill or meet the reason you provided the information; provide you with our website, applications, products, and services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; to satisfy our legal obligations; market to you.
For job applicants: Assess your application. | Social networks; technology service providers; data analytics providers; customer relationship management providers; background check providers (for job applicants); clients. | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer. |
California Customer Records personal information (Cal. Civ. Code § 1798.80(e)), including 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. | Directly from you.
For job applicants: Recruiters; background check providers. | Fulfill or meet the reason you provided the information; provide you with our website, applications, products, and services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors; to satisfy our legal obligations; market to you.
For job applicants: Process your application. | Technology service providers; customer relationship management providers; background check providers (for job applicants; clients. | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or (7) years post-relationship, whichever is longer. |
Characteristics of protected classifications under California or federal law. | Directly from you.
For job applicants: Recruiters, background check providers. | Meet our legal obligations. | Background check providers (for job applicants). | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or (7) years post-relationship, whichever is longer. |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Directly from you; indirectly from you as you navigate or use our website, applications, or services; advertising networks; internet service providers; data analytics providers. | Maintain transaction records; provide you with our products or services; provide you with advertising or marketing services. | Service providers and contractors such as payment processors; customer relationship management providers; data analytics providers; advertising networks; clients. | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or (7) years post-relationship, whichever is longer. |
Biometric information. | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. | Indirectly from you as you navigate or use our website, applications, or services; advertising networks; internet service providers; data analytics providers.
| Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; verify, maintain, improve, upgrade, or enhance a service or device that is owned or controlled by us; identify and repair errors; provide you with advertising or marketing services; perform analytics. | Advertising networks; technology service providers; data analytics providers. | Barring any legally required additional retention period, up to one year. |
Geolocation data | Indirectly from you; devices you use to access our website, applications, or services; advertising networks; data analytics providers. | Protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors. | Advertising networks; technology service providers; data analytics providers.
| Barring any legally required additional retention period, up to one year. |
Sensory data including audio, electronic, visual, or similar information. | Directly from you. | Protect and secure our environment; verify, maintain, improve, upgrade, or enhance a product or service; identify and repair errors. | Not applicable. | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or (7) years post-relationship, whichever is longer. |
Professional or employment-related information. | For job applicants: Directly from you; recruiters. | For job applicants: Process your application. | Background check providers (for job applicants). | Barring any legally required additional retention period, up to (7) years for non-hired applicants. |
Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99) | For job applicants: Directly from you; recruiters. | For job applicants: Process your application. | Background check providers (for job applicants). | Barring any legally required additional retention period, up to (7) years for non-hired applicants. |
Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Indirectly from you; devices you use to access our website, applications, products, or services; advertising networks; data analytics providers. | Provide you with advertising or marketing services; perform analytics; maintain, improve, upgrade, or enhance our website, applications, products or services. | Advertising networks; technology service providers; data analytics providers. | The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or (7) years post-relationship, whichever is longer. |
Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140 | Sources from which Information was Collected | Purposes for Collection; Use | Third Parties, Service Providers, and Contractors Receiving Personal Information | Retention Period |
Social security number, driver’s license number, state identification card, or passport number. | For job applicants: Recruiters; background check providers. | For job applicants: Process your application; satisfy legal obligations. | Background check providers (for job applicants); clients.. | Barring any legally required additional retention period, up to (7) years for non-hired applicants. |
Account access credentials (user names, account numbers, or card numbers combined with required access code, security code or password to access an account). | Directly from you. | Fulfill or meet the reason you provided the information; provide you with our products and services; protect and secure our environment. | Not applicable. | The length of your business relationship with us or 90 days, whichever is longer. |
Precise geolocation (location within a geographical area of a circle with a radius of 1850 feet or less). | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Racial or ethnic origin | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Religious or philosophical beliefs | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Union membership | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Genetic Data | We do not collect. | We do not collect. | Not applicable. | Not applicable. |
Mail, email, or text messages where the content is not directed to us. | We do not collect. | Not applicable. | Not applicable. | Not applicable. |
Unique identifying biometric information | We do not collect. | We do not collect. | Not applicable. | Not applicable. |
Personal information collected and analyzed concerning health. | We do not collect. | We do not collect. | Not applicable. | Not applicable. |
Personal information collected and analyzed concerning sex life, or sexual orientation. | We do not collect. | We do not collect. | Not applicable. | Not applicable. |
Right to Limit Use and Disclosure of Sensitive Personal Information
We collect sensitive personal information for the purpose of inferring characteristics about consumers. If you would like to limit the use of your sensitive personal information, you may do so using our Limit the Use of My Sensitive Personal Information link.
Right to Opt Out of Sharing for Cross-Context Behavioral Advertising
In the past twelve months we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to advertising networks, data analytics providers, and social media networks for this purpose:
- Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data.
If you would like to opt out of this sharing, you may exercise your right using our Do Not Sell My Personal Information link, by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, click here.
Right to Opt Out of Sale
While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include actives such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to advertising networks, data analytics providers, and social media networks in ways that could be considered a “sale” under California law:
- Personal identifiers, such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, and unique advertising identifiers and cookies; Internet and other electronic network activity information; geolocation information; and inference data.
We disclosed these categories of information to these third parties in order to market and advertise our products and services; perform analytics; and to maintain, improve, upgrade, or enhance our products or services.
We have no actual knowledge of selling the personal information or sensitive personal information of minors under 16 years of age.
California residents have the right to opt out of the “sale” of their personal or sensitive personal information.
If you would like to opt out of such disclosures, you may exercise your right using our Do Not Sell or Share My Personal Information link, by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, click here.
Third Parties to Whom We Have Disclosed Personal Information
We have disclosed personal information in all or substantially all of the categories identified in this Privacy Notice for business purposes to the following categories of third parties over the past twelve months:
- Third party service providers.
- Joint marketing partners.
- Affiliates.
- Clients.
We also share information about your physical location with our affiliates, clients, joint marketing partners, and other third parties to , for example, enhance location-based services. In addition, except as described below, unless you opt out, we may share other personal information with third parties for those parties’ own purposes, such as to offer products or services that may interest you.
Your Rights and Choices
Right to Access Personal Information.
You have the right to request the categories and specific pieces of personal information we have collected about you.
Right to Delete Personal Information.
You have the right to request that we delete personal information that we have collected from you.
Right to Correct Inaccurate Personal Information.
You have the right to request the correction of any inaccurate personal information that we maintain about you.
Right to Non-Retaliation and Non-Discrimination.
You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. We do not retaliate or discriminate against you for exercising the privacy rights conferred to you under the CCPA.
Financial Incentive.
We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior consent, which you may revoke at any time.
Exercising Your Rights
To exercise your rights, you may contact us via phone at 800.633.9404 or via email at privacy@randallreilly.com. You may also submit a request through our website by visiting our Web Form. Please note that we will ask for additional information to match with information we have on file in order to verify your identity before acting on your request to exercise your rights. The personal information that we use to verify your identity will not be used for any other purpose.
You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. We may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.
How To Contact Us
If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please contact us by sending an email to privacy@randallreilly.com.
You also may write to us at:
Randall-Reilly, LLC
Data Privacy Team
3200 Rice Mine Road, NE
Tuscaloosa, Alabama 35406.
Should you have a disability that prevents or limits your ability to access this policy, please email us at privacy@randallreilly.com or call us at 800.633.9404. We will work with you to provide this notice in an alternative format.
