CCPA

Weintraub Tobin

California Supplemental Privacy Notice

Effective Date: January 1, 2020

SUMMARY OF PERSONAL INFORMATION THAT WE COLLECT ABOUT YOU

For individuals who are California residents, we have adopted this California Privacy Policy (the “CA Privacy Policy”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws, which require certain disclosures about the categories of personal information we collect, how we use them, the categories of sources from whom we collect personal information, and the third parties with whom we share it. This CA Privacy Policy is supplementary to the general privacy policy (“Privacy Policy”) for Weintraub Tobin Chediak Coleman Grodin Law Corporation and its subsidiaries and affiliates (collectively, the “Company”).  All undefined capitalized terms used herein shall have the same meaning as set forth in the Privacy Policy.  By using the Website, you consent to the collection and use of your “personal information” (as that term is defined below) as described in this CA Privacy Policy.

Depending on how you interact with the Company, we may collect certain categories of information as summarized in the table below. This CA Privacy Policy does not apply to personal information we collect from employees or job applicants in their capacity as employees or job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services. Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• 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.

SOURCES OF PERSONAL INFORMATION COLLECTED

All of the categories of personal information we collect about you (as detailed below) come from the following types of sources:

• From you or your representatives, including through your use of our services.
• Automatically collected from you or your representatives.
• Automatically through your or your representative’s activity on our Website.
• From third parties that interact with us in connection with the services we provide.

CATEGORIES OF PERSONAL INFORMATION COLLECTED IN THE LAST TWELVE MONTHS

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, household or device (“personal information”). In particular, we have collected the following categories of personal information from consumers during the twelve (12) months prior to the Effective Date of this CA Privacy Policy:

Category	Examples	Collected
A. Identifiers.	A name, signature alias, physical characteristics or description, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, passport number, telephone 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, or other similar identifiers.	YES
B. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
C. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
D. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
E. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
F. Geolocation data.	Physical location or movements.	YES
G. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
H. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
J. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

BUSINESS/COMMERCIAL PURPOSES FOR OUR USE OF PERSONAL INFORMATION

All of the categories of personal information we collect about you (as detailed above) are used for the following purposes:

• Providing our services (for example, account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our services).
• Providing email alerts, event registrations, and other notices concerning our products or services, or other events or information that may be of interest to you.
• For our operational purposes, and the operational purposes of our service providers and integration partners.
• To enable efficient logins to our hardware and systems.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Improving our existing services and developing new services (e.g., by conducting research to develop new services, products, or features).
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity.
• Bug detection, error reporting, and activities to maintain the quality or safety of our services.
• Auditing consumer interactions on our site (for example, measuring page views).
• Short-term, transient use, such as customizing content that we or our service providers display on the services.
• Other uses that advance our commercial or economic interests, such as communicating with you about relevant offers.
• Such other uses that we notify you about when collecting your personal information or otherwise.

CATEGORIES OF THIRD PARTIES WITH WHOM WE HAVE SHARED PERSONAL INFORMATION IN THE LAST TWELVE MONTHS

We may disclose your personal information to a third party for a “business purpose” (as that term is defined in the CCPA).  In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category	Specific Information Collected	Categories of Third Parties with Whom We Share Personal Information
A. Identifiers.	A name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other similar identifiers.	-Third parties (such as our service providers, integration partners, and our social media accounts) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services) -Opposing parties, courts, governmental entities involved in a dispute or transaction.
B. Protected classification characteristics under California or federal law.	Citizenship, marital status, sex (including gender, gender identity, and gender expression), veteran or military status.	-None
C. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	-Third parties (such as our service providers and integration partners) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services) -Opposing parties, courts, governmental entities involved in a dispute or transaction.
D. Biometric information.	Fingerprints, gait, or other physical patterns.	-None
E. Internet or other similar network activity.	Browsing history, search history, and information on a consumer’s interaction with a website.	-Third parties (such as our service providers and integration partners) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services)
F. Geolocation data.	Physical location.	-Third parties (such as our service providers and integration partners) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services)
G. Sensory data.	Audio, electronic, visual, thermal,  or similar information.	-Third parties (such as our service providers, integration partners, and our social media accounts) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services) -Opposing parties, courts, governmental entities involved in a dispute or transaction.
H. Professional or employment-related information.	Current or past job history.	-Third parties (such as our service providers, integration partners, and our social media accounts) or you and/or your organization (through the process of evaluating or engaging in an attorney-client relationship with us) -Aggregators (such as analytics services)
I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	N/A	N/A
J. Inferences drawn from other personal information.	N/A	N/A

YOUR RIGHTS AND CHOICES

Subject to certain restrictions, California residents have the right to request that we disclose what personal information we collect about you, to delete any personal information that we collected from or maintain about you, and to opt-out of the sale of personal information about you. As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us either through our email at privacy@weintraub.com or call us toll-free at (833) 982-1978.

Accessing and Deleting Your Personal Information

• Right to request access to your personal information

California residents have the right to request that we disclose what categories of personal information that we collect, use, disclose, or sell about you. You may also request the specific pieces of personal information that we have collected about you. However, we may withhold some information where the risk to you, your personal information, or our business is too great to disclose the information.

• Right to request deletion of your personal information

You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.

• How to exercise your access and deletion rights

California residents may exercise their California privacy rights by submitting your request to us either through our email at privacy@weintraub.com or call us toll-free at (833) 982-1978.

For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights so we can reasonably verify you are the person about whom we collected such personal information (or that person’s authorized representative).

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to an additional 45 days), we will inform you of the reason and the extension period in writing.  If you have an account with us, we will deliver our written response through your account.  If you do not have an account with us, we will deliver our written response by mail or electronically as you so request.  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.  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Once you submit a request to (1) access the categories of personal information we have about you or (2) obtain a copy of specific pieces of personal information we have about you, we will ask that you verify you identity by logging into your account using your username and password. There, we will provide you with your information in a password-protected format.

To request that we delete personal information we have collected from you, you will need to authenticate with us by first logging into your account using your user name and password on file with us and deleting your account, once you let us know you’ve taken this action we will initiate the deletion process.

If you wish to exercise any of these rights and do not have an account with us, please contact us either through our email at privacy@weintraub.com or call us toll-free at (833) 982-1978 and we will request additional information to perform identity verification where possible.

Sales of Personal Information

California residents may opt out of the “sale” of their personal information. The Company does not “sell” your personal information as we understand that term to be defined by the CCPA and its implementing regulations.

Non-Discrimination Rights

California residents have the right to not be discriminated against for exercising their rights as described in this section. We will not discriminate against you for exercising your CCPA rights.