This Privacy Notice at Collection applies to personal information of California residents to the extent the information is subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020 (“CCPA”). This notice does not apply to personal information collected pursuant to (i) the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; or, (ii) certain medical and health information covered by HIPAA. The CCPA applies to some, but not all, of our affiliated companies. Therefore, consumers whose information is processed by our affiliates that are not subject to the CCPA would not be entitled to the rights, or subject to the disclosures, provided below. Most information we collect and process is subject to the Gramm-Leach-Bliley Act or otherwise exempt from the CCPA. Personal information subject to the CCPA that we process is primarily in the context of hiring, employment, business-to-business communications, and our website.
Personal Information We Collect
We collect or use information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may collect or use the following categories of your personal information in the following ways:
| Category of Personal Information | Examples of Personal Information Collected or Used | Expected Retention Period or Criteria for Retention | Is the Category of Personal Information Shared? | Business or Commercial Purpose(s) for Which Used or Collected |
|---|---|---|---|---|
| Identifiers | Includes direct identifiers, such as Name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; SSN, driver’s license number, passport number, tax ID and other government identifiers; and other similar identifiers. | Personal Information is retained based on internal retention policies and segregated by category of information in accordance with various local, state, federal, and other legal requirements. Personal Information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes. Personal Information is subject to appropriate disposal, along with other business records, in the ordinary course. | We do not share personal information for purposes of cross context behavioral advertising. |
|
| Personal Information Categories Listed in the California Customer Records statue (Cal. Civ. Code 1798.80(e)) | Includes personal information, such as name, account name, user ID, contact information, education and employment information, SSN and government identifiers, account number, and financial or payment information), that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual registers for an account, purchases or orders our products and services, or enters into an agreement with us related to our products and services. | |||
| Characteristics of protected classifications under California or federal law | Includes characteristics of protected classifications under applicable/federal and state/federal and California laws, such as disability information and medical conditions (e.g., which we may collect in order to make available appropriate accommodations for events and other activities or TTY services). | |||
| Commercial Information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers. | |||
| Biometric Information | We do not collect Biometric Information. | |||
| Internet or other electronic network activity information | Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online ads. | |||
| Geolocation data | Includes precise location information about a particular individual or device. | |||
| Sensory Data | Includes audio, electronic, visual, thermal, olfactory, or similar information such as photographs and images (e.g., that you provide us or post to your profile) and call recordings (e.g., of customer support calls). | |||
| Professional or employment-related information | Includes professional and employment-related information (such as current and former employer(s) and position(s), business contact information and professional memberships). | |||
| 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)) | Information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates). | |||
| Inferences drawn from other personal information | Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads. | |||
| Sensitive Personal Information | Includes a consumer’s social security, driver’s license, state identification card, or passport number. A consumer’s 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 an account. A consumer’s precise geolocation. A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. Also includes A consumer’s genetic data and the processing of biometric information for the purpose of uniquely identifying a consumer. Also includes Personal information collected and analyzed concerning a consumer’s health. | For human resources purposes. |
We do not sell personal information. We do not share personal information for the purpose of cross-context behavioral advertising.
We do not sell or share the personal information of minors under 16 years of age. We do share cookies with third parties as described in our online privacy policy. To opt-out of the sharing of information with third parties in this context, please review our online privacy policy for instructions or adjust your browser settings accordingly.
Further Information
Please visit our website and our privacy policy for further information about personal information we collect, and your rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020.
If you have questions about this notice, please contact us at:
Phone: (888) 413-0444
Website: http://www.ltcglobal.com/privacy-compliance.html
Email: compliance@ltcglobal.com