Privacy Notice

ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Last Updated: September 7, 2023

Scope of Disclosures

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our PRIVACY NOTICE and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). For a detailed description of how we collect, use, disclose, and otherwise process personal information, please see our PRIVACY NOTICE.

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our PRIVACY NOTICE or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available, that is deidentified or aggregated such that it can no longer reasonably be used to infer information about, or otherwise be linked to, you, or that is otherwise excluded from the CCPA’s scope.

Personal Information

As described in more detail in the Our Collection of Personal Information section of our PRIVACY NOTICE, we collect the following categories of personal information:

• Identifiers, such as first and last name, phone number, email address and IP address.

• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as mailing address, email address, phone number, state and country of residence, and information about your status and holdings as an investor.

• Commercial Information, such as product or service interests and orders.

• Internet/Network Information, such as log file data (including operating system and browser type) and clickstream data (including your usage and activity on our web sites and online services).

• Geolocation Data, such as your general geographic location based on your IP address.

• Sensory Information,such as the sound of your voice from calls with us or your image when you visit our facilities (where permitted by law).

• Professional/Employment Information, such as your title, company name, professional background, the nature of your relationship with us, the nature and length of your relationship with current and prior employers, and other professional / employment information you choose to share in connection with a job application.

• Education Information, such as education history shared in connection with your job application (including schools attended and degrees achieved).

• Sensitive Personal Information, solely in connection with your job application where voluntarily provided or otherwise collected in accordance with law, such as account credentials for our careers page,  social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, and personal information concerning health (such as accommodation requests). 

• Other Personal Information, such as inquiries, requests or comments you choose to send us.

• Inferences, such as predictions about which services may be of interest to you and your employer.

We collect this information directly from you, from your browser or device when you interact with our services, and from our affiliates, your employer, recruiters, references, professional networks, service providers, information providers and other publicly available sources. For more information about the personal information we collect and how we collect it, please refer to the Our Collection of Personal Information section of our PRIVACY NOTICE.

We collect personal information from and about you for a variety of purposes. For example, we use personal information to communicate with customers about our services, to provide customers with our services, to facilitate investor services, to process job applications, and to otherwise operate our business. For more information about our use of personal information, please refer to the Our Use of Personal Information section of our PRIVACY NOTICE.

Sensitive Personal Information

We only use sensitive personal information for the purposes set forth in the Our Use of Personal Information section of our PRIVACY NOTICE to the extent necessary to process your job application at your request, to enter into and perform a contract with you, to comply with legal and regulatory requirements, to protect the life or physical safety of anyone or as otherwise permissible for our own internal purposes consistent with laws.

Deidentified Information

We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

Disclosure, Sale and Sharing of Personal Information

As further described in the Our Disclosure of Personal Information section of our PRIVACY NOTICE, we may disclose all of the personal information identified above to third parties for business purposes. The categories of third parties to whom we disclose personal information for these purposes include our affiliates, the business you represent, data analytics providers, marketing partners, service providers, and certain other third parties where you have provided your consent or direction, we are engaging in a business transaction or reorganization, or we are addressing our legal obligations and rights.

As is common practice among companies that operate online, we also allow certain third-party providers to use cookies and related technologies to collect Identifiers (such as IP address), Commercial Information (such as products sold or considered), Internet/Network Information (such as analytics data), and Inferences (generated from your interactions with us) directly through our websites and other online services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. Some of these practices may constitute the sale of personal information or the use of personal information for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”). Subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the sharing of personal information for purposes of targeted advertising (as described in the Your California Privacy Rights section below).

We do not otherwise sell personal information or share personal information for purposes of targeted advertising. We also do not sell the personal information of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes. In addition, we do not sell sensitive information or share sensitive information for purposes of targeted advertising, nor use sensitive information for the purpose of inferring characteristics about a consumer in a manner that would require our offering of the right to limit the use of such information.

Retention of Personal Information

We retain personal information only for as long as is reasonably necessary to fulfil the purpose for which it was collected.  However, if necessary, we may retain personal information for longer periods of time, until such retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, or accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and whether we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights (subject to certain limitations at law):

The Right to Know	The right to confirm whether we are processing personal information about you and to obtain certain personalized details about the personal information we have collected about you, including: The categories of personal information collected; The categories of sources of the personal information; The purposes for which the personal information was collected; The categories of personal information disclosed to third parties (if any) and the categories of recipients to whom this personal information was disclosed; The categories of personal information shared for cross-context behavioral advertising purposes (or, “targeted advertising”) (if any), and the categories of recipients to whom the personal information was disclosed for those purposes; and The categories of personal information sold (if any), and the categories of third parties to whom the personal information was sold.
The Right to Access & Portability	The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
The Right to Correction	The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
The Right to Opt-Out of Targeted Advertising	The right to direct us not to share personal information for certain cross-context behavioral or targeted advertising purposes.
The Right to Opt-Out of Sales	The right to direct us not to sell and/or share personal information for certain cross-context behavioral or targeted advertising purposes.
The Right to Request Deletion	The right to request the deletion of personal information that we have collected from you.

You also have the right not to receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, please note that if the exercise of these rights limits our ability to process personal information, we may no longer be able to engage with you in the same manner.

How to Exercise Your California Privacy Rights

To Exercise Your Right to Know, Access, Portability, Correction, or Deletion

To submit a request to exercise the right to know, access, portability, correction and/or deletion, please submit a request by:

• Emailing [email protected] with the subject line “California Rights Request,” or
• Submitting this form via our website.

Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  Although we try to limit the personal information collected in connection with a request to that personal information identified on our webform certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline or limit a request, particularly where we are unable to verify your identity.

To Exercise Your Right to Opt Out of Personal Information Sales or Sharing for Targeted Advertising Purposes

To submit a request to exercise the right to opt out of personal information sales or sharing for targeted advertising purposes, please submit a request by:

• For Non-Cookie-Based Opt-Outs:
  • Emailing [email protected] with the subject line “California Rights Request,” or
  • Submitting this form via our website.
    
• For Cookie-Based Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, please click the cookie icon on the bottom right-hand corner of your screen and adjust your cookie preferences. This opt-out tool is device- and browser-specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting www.privacyrights.info. Lastly, you may follow the other steps set forth in our PRIVACY NOTICE to further exercise control over cookies and related technologies.

Once you make an opt-out request, you may change your mind and opt back in at any time by contacting us at [email protected] (for non-cookie-based opt-outs) and/or adjusting your cookie preferences as described above (for cookie-based opt-outs).

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.