California Consumer Privacy Act Policy

This document provides specific information for California residents, as required under the California Consumer Privacy Act (“CCPA”).  The CCPA requires that we provide California residents information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement.  Our Privacy Policy and Privacy Notice further describe our policies and practices relating to privacy.

Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household. 

Notice at Collection: Categories of Personal Information that We Collect or Disclose

Below please find the categories of personal information about California residents that we collect and/or disclose to third parties or service providers for a business purpose.


Categories of personal information (Last updated 01/01/2020) Do we collect? Do we disclose for business purposes? Do we sell?
Name, Contact Information and Identifiers: 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 Yes No
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, social security number, Signature, physical characteristics or description, address and location from which customer interactions with us occur, 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 Yes No
Protected Classifications: Characteristics of protected classifications under California or federal law such as race (only at the individual’s option), sex, age, national origin, disabilities, and citizenship status. Yes Yes No
Purchase History and Tendencies: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes Yes No
Biometric Information: Physiological or biological characteristics that can be used alone or in combination with each other to establish individual identity, including fingerprint, face, hand, palm, and voice recordings. Yes Yes No
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. Yes Yes No
Geolocation Data: Precise geolocation location information about a particular individual or device. Yes Yes No
Audio/Visual: Audio, electronic, visual, thermal, olfactory, or similar information. Yes Yes No
Employment History: Professional or employment-related information. Yes Yes No
Education Information: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). Yes Yes No
Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, and characteristics. We may collect the following about employees’ and job applicants’ on behavior, attitudes, intelligence, abilities, and aptitudes. Yes Yes No

California Residents’ Rights

California law grants California residents’ certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell: We do not sell your personal information.

Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests for Copy, Deletion and Right to Know: Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

Right of Deletion: The right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
  • 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 his or her 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 the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
  • Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
  • Comply with a legal obligation.
  • Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Please note that the great majority of personal information we collect falls into the foregoing exemptions.

Right to a Copy: (Up to twice every twelve months) The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.  For security reasons, certain highly sensitive types of personal information, such as social security numbers, drivers’ license numbers, and bank account numbers, will not be provided but we will inform you if we may have collected them during such 12-month period.

Right to Know: (Up to twice every twelve months) The right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

  • Categories of personal information collected;
  • Categories of sources of personal information;
  • Business and/or commercial purposes for collecting and selling their personal information;
  • Categories of third parties/with whom we have disclosed or shared their personal information;
  • Categories of personal information that we have disclosed or shared with a third party for a business purpose;
  • Categories of personal information collected; and
  • Categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

Submitting Requests: Requests to exercise the right to deletion, right to a copy, and/or the right to know may be submitted at or by contacting us at 1-800-427-2200. We will respond to verifiable requests received from California consumers as required by law.   

Incentives and Discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information. 

Discrimination: Businesses may not discriminate against residents who exercise their rights under CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices or rates or impose penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, residents have the right to be notified of any financial incentives offers and their material terms, the right not be included in such offers without prior informed opt-in consent, and the right to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any such incentives at this time.