Supplemental Privacy Notice for California Residents

Last updated: 02/12/2021

This Supplemental Privacy Notice for California Residents supplements the information contained in our Privacy Notice and applies to California residents (consumers) who visit or use the Website. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. Any capitalized terms not defined in this notice or in the CCPA have the meaning provided in our Privacy Notice.

This notice outlines the personal information we collect or process about you if you are a consumer when you access or use the Website or the services we provide or offer specifically to you through the Website; how we use, share, and protect that personal information; and what your rights are with respect to your personal information that we gather and process.

In this notice, personal information has the same meaning as under the CCPA: 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. Personal information does not include publicly available information or information that has been de-identified or aggregated.

The CCPA also excludes from its scope certain other information, including (but not limited to):

health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or clinical trial data; and
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.

Categories of personal information we collect

We may collect the personal information described in 'The data we collect about you' section of our Privacy Notice. We will not collect additional categories of personal information without providing you notice.

We have collected the following categories of personal information within the last twelve (12) months:

Category	Description	Collected
(A)	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.	Yes
(B)	Any categories of personal information described in subdivision (e) of Section 1798.80. i.e.: any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.	Yes
(C)	Characteristics of protected classifications under California or federal law. Examples: Age, 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 (limited to Template Data provided by you)
(D)	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
(E)	Biometric information. Defined as: an individual's physiological, biological, or behavioral characteristics, including an individual's deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No
(F)	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement.	Yes
(G)	Geolocation data.	No
(H)	Audio, electronic, visual, thermal, olfactory, or similar information.	No
(I)	Professional or employment-related information.	Yes
(J)	Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). Examples: 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.	No
(K)	Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Use of personal information

We may use the personal information we collect for the business or commercial purposes listed in the 'How we use your personal data' section of our Privacy Notice. We will not use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sources of personal information

We may obtain the categories of personal information listed above from the sources described in the 'How is your personal data collected?' section of our Privacy Notice.

Sharing personal information

We may disclose your personal information to the categories of third parties described in the 'Disclosures of your personal data' section of our Privacy Notice. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business or commercial purpose:

Category	Description	Disclosed
(A)	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.	Yes
(B)	Any categories of personal information described in subdivision (e) of Section 1798.80. i.e.: any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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.	Yes
(C)	Characteristics of protected classifications under California or federal law. Examples: Age, 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).	No
(D)	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
(E)	Biometric information. Defined as: an individual's physiological, biological, or behavioral characteristics, including an individual's deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No
(F)	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement.	No
(G)	Geolocation data.	No
(H)	Audio, electronic, visual, thermal, olfactory, or similar information.	No
(I)	Professional or employment-related information.	No
(J)	Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). Examples: 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.	No
(K)	Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Sales of personal information

We do not sell your information as defined under the CCPA.

Your rights and choices

The CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

However, neither these rights in particular, nor the CCPA in general, restrict our ability, amongst other things, to:

Comply with federal, state, or local laws.
Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities.
Co-operate with law enforcement agencies concerning conduct or activity that we, a service provider of ours, or a third party reasonably and in good faith believes may violate federal, state, or local law.
Exercise or defend legal claims.
Collect or sell a consumer's personal information if every aspect of that commercial conduct takes place wholly outside of California.

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 over the past 12 months:

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(s) for collecting or selling that personal information.
The categories of third parties with whom we shared that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold your personal information, the categories of personal information that each category of recipient purchased.
If we disclosed your personal information for a business purpose, the categories of personal information that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request (see 'Exercising access, data portability, and deletion rights' below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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 you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
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.
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.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with a legal obligation.
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to opt out or opt In

If you are a consumer, you have the right to opt out of having your personal information sold to third parties. However, because we do not sell personal information for monetary or other valuable consideration and have no plans to do so, we are not required to provide any mechanism for you to exercise the right to opt out.

If you are a consumer under the age of 16 but at least 13, you have the right to only have your information sold if you opt in and affirmatively authorize the sale of your personal information; if a consumer child is less than 13, then the child's parent or guardian must opt in and affirmatively authorize the sale of personal information. However, to avoid any doubt, we do not sell personal information for monetary or other valuable consideration and have no plans to do so. Further, we do not knowingly collect personal information from minors; our services are for use by adults.

Do not track signals and direct marketing

Some web browsers have the ability to set 'Do not track' requests to block user activity from being tracked across web pages or devices.

However, the Website does not recognize Do not track browser signals.

California's 'Shine the Light' law (Civil Code Section § 1798.83) permits users of the Website that are consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by email at support@epoqlegal.com .

Right of non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not, as a result of you exercising any of your CCPA rights:

Deny you services.
Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of services.
Suggest that you may receive a different price or rate for services or a different level or quality of services.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, you must make a verifiable consumer request by email at support@epoqlegal.com .

Only you, or an agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, see 'Authorized Agents' below. You may also make a verifiable consumer request on behalf of your minor child.

We may request additional information so we may confirm a request to delete 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 you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Making a verifiable consumer request does not require you to create an account with us, although we may communicate with you about your request via a pre-established account, if applicable. However, in order to safeguard the personal information in our possession, if we cannot verify your identity or authority to act on another's behalf, we will be unable to comply with your request. We will only use personal information you provide when submitting a verifiable request to confirm your identity or authority, or to fulfill your request.

Authorized Agents

You may authorize an agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized to exercise your rights on your behalf. We may request that your authorized agent submit proof of identity. We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

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 in total), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, 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.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to this Supplemental Privacy Notice for California Residents

We reserve the right to amend this notice at our discretion and at any time. The date this notice was last updated is identified at the top of this page. You are responsible for periodically visiting the Website and this notice to check for any changes.

Contact us

If you have any questions or comments about this Supplemental Privacy Notice for California Residents, the ways in which we collect and use your information described in this notice or in Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to please contact us by email at support@epoqlegal.com .

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