This policy applies to all visitors, users and others. This policy is intended to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. This policy is also intended to comply with the General Data Protection Regulation of 2018 (GDPR).
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from its requirements.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we have collected the following categories of personal information from consumers within the last twelve months:
|A. Identifiers.||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. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A 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.
Some personal information included in this category may overlap with other categories.
|C. 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|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. 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.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. 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|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
- Government Entities.
- Internet Cookie Data Recipients, like Google Analytics.
- Parent or Subsidiary Organizations.
- Service Providers.
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- In order to process any orders for products or services, we may send your data to, and also use the resulting information from, credit reporting agencies to prevent fraudulent purchases.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users or consumers is among the assets transferred.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
We may also share your personal information by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not include information about individuals we know are under age 16. In the preceding twelve (12) months, Company has not sold personal information to any third parties. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|B: California Customer Records personal information categories.||NONE||NONE|
|C: Protected classification characteristics under California or federal law.||NONE||NONE|
|D: Commercial information.||NONE||NONE|
|E: Biometric information.||NONE||NONE|
|F: Internet or other similar network activity.||NONE||NONE|
|G: Geolocation data.||NONE||NONE|
|H: Sensory data.||NONE||NONE|
|I: Professional or employment-related information.||NONE||NONE|
|J: Non-public education information.||NONE||NONE|
|K: Inferences drawn from other personal information.||NONE||NONE|
Reselling Personal Information
- The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. We do not sell personal information to third parties that may resell that information.
Deidentified Patient Information
We do not sell and/or disclose deidentified patient information exempt from the CCPA to third parties.
Storage of Your Data
We securely store your data servers located in covington, kentucky, with data replication to servers in denver, colorado and take the following security precautions to protect your data: the servers that house our data are encrypted at rest and all access to data is limited to authorized individuals via an encrypted connection to the servers.
We will keep your data subject to our standard data retention policy.
We would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please click ***still need this***.
Your Rights and Choices
Right to Know
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 “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will disclose to you:
- 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 for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide a right to know or data portability disclosure for B2B personal information.
Right to Rectification
You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information that you believe is incomplete.
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information 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 we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We do not provide these deletion rights for B2B personal information.
Right to Restrict Processing
You have the right to request that we restrict the processing of your personal data, under certain circumstances.
Right to Object to Processing
You have the right to object to our processing of your personal data, under certain conditions.
Right to Data Portability
You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Exercising Your Rights
To exercise any of these rights described above, please submit a request by either:
- Calling us at 800-705-7855.
- Submitting a request through https://***STILL NEED THIS***
- Emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may exercise any of these rights related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request exercise any of these rights must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- In order to very your identity, you will be required to provide at least two data points that match data points that we maintain. In the event that a request involves certain highly sensitive information, we will require you to provide at least three data points that match data points that we maintain in order to verify identity. .
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us by either:
- Calling us at 800-705-7855.
- Emailing us at email@example.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days (thirty (30) days in the case of a request made under GDPR) of its receipt. If we require more time (up to another 45 days), 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 that 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 our receipt of your request. 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.
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Functionality — Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising — Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
Do Not Sell My Personal Information
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:
***OPT-IN INSTRUCTIONS OR URL LINK***
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
If you have any questions or comments about this notice, the ways in which Wood + Lamping LLP collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: ***STILL NEED THIS***
Wood + Lamping LLP
Attn: Chief Operating Officer
600 Vine Street, Suite 2500, Cincinnati, Ohio 45202
If you need to access this Policy in an alternative format due to having a disability, please contact firstname.lastname@example.org or 800-705-7855.
How to Contact the Appropriate Authority
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office. A list of offices, including contact information, can be found at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.