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California Privacy Statement Addendum

California Privacy Statement Addendum

06 June 2020

Introduction

This addendum to the Aprio, LLP privacy statement explains the categories of personal data that we collect from you and how we collect and use personal data that is subject to the California Consumer Privacy Act of 2018 (the “CCPA”).  It further describes the rights that California residents have with respect to their personal data. This addendum should be read together with the Aprio, LLP privacy statement, and in case of any conflict the terms of this addendum will prevail as to personal data of California residents that is subject to the CCPA.  For purposes of this addendum, the term “personal data” includes all “personal information” as defined in the CCPA.

Your legal rights

Aprio, LLP generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

Under certain circumstances, California residents have the following rights in relation to their personal data:

  • Right of access and data portability. You may have the right to request that we disclose to you information about our collection and use of your personal data in the preceding 12 months, including: (a)  the categories and specific pieces of personal data we collect; (b) the categories of sources from which we collect or sell personal data; (c) the business or commercial purpose for which we collect personal data; (d) the categories of third parties with whom we share personal data; and (e) the categories of personal data disclosed for a business purpose or sold to third parties and the categories of third parties to whom such personal data was sold or disclosed.
  • Right to deletion. You may request that we delete certain personal data that we have collected about you.  The foregoing is subject to our right to maintain your personal data for specific purposes permitted under CCPA.  If we are unable to comply with any such request, we will notify you.
  • Right to opt-out. You may have the right to request that your personal data not be used for any other reason than business purposes.
  • Right to non-discrimination. You have the right to exercise any of the rights listed above (and any other rights under CCPA) without discrimination by us or any additional charges or cost.

Sources of, purposes for collecting, and categories of personal data collected and disclosed

We collect and process personal data for a variety of business or commercial purposes. In the preceding twelve (12) months, we have collected the following categories of personal data from California residents. Please note that the following list represents categories of personal data across all California residents whose personal data we may have collected or received and does not necessarily represent information we have collected specifically about you. Please also note that the definition of “personal information” under CCPA is subject to certain exceptions as set forth therein and does not include information that is publicly available or has been aggregated or deidentified in accordance with CCPA.

  • This includes information such as name, postal address, email address, internet protocol address, driver’s license number and other similar identifiers.
  • Personal information as defined by Cal. Civ. Code § 1798.80(e). The type of personal data in this category includes several of the identifiers described above but also includes, among other things, information such as social security number, bank account number, credit card number, debit card number and employment information.
  • Internet or network activity. The type of information in this category includes information that relates to browsing or search history, or information regarding visitors’ interaction with an internet website.

In the preceding 12 months, we may have disclosed to third parties for a business purpose the categories of personal data listed above.

Sales of personal data

We do not sell your personal data for monetary consideration. We may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other personal data via automated technologies on aprio.com in exchange for non-monetary consideration.  We may share the categories of personal data listed below in order to improve the performance of aprio.com, to enhance your browsing experience, to provide you a more personalized browsing experience, and to improve our advertising efforts. You can view a full listing of those third-party cookies and opt out of their use via the aprio.com cookie settings page here.  Please note that to the extent you are accessing aprio.com across multiple devices or platforms or if you clear your browser settings, you may have to opt out again.

In the preceding 12 months we may have sold the following categories of personal data in connection with such third-party cookies:

  • This includes aprio.com visitors’ internet protocol (“IP”) addresses.
  • Internet or network activity. This includes information about visitors’ interaction with aprio.com, including information about the visitor’s web browser, page location, referrer, and person using the website; cookie-specific data such as cookie ID and the cookie; and button and field data, such as any buttons clicked by site visitors, the labels of those buttons, any pages visited as a result of the button clicks, and the names of any website fields filled in by visitors.

Children

In addition to our Aprio, LLP privacy statement for children, CCPA requires that an individual under the age of 16 must provide opt-in consent for their personal information to be sold. Children under the age of 13 must provide valid parental consent for their information to be sold.

Exercising your rights in relation to personal data

If you would like to exercise any of the rights you may have with respect to personal data under the CCPA as listed above, please contact us by either:

  • Completing and submitting a request form here, or
  • Contacting us by phone at (781) 789-2082.

As part of processing your request, we require you to provide certain personal data in order to verify your identity in accordance with the CCPA requirements. This information includes your first and last name, email address, physical address, telephone number, and description of relationship to Aprio, LLP, but may also include additional information based on the nature of your request and your relationship with us.

Additionally, in accordance with your rights under the CCPA, you may designate an authorized agent to make a request on your behalf. In order to comply with your request, we will require the personal data referenced above to be used for identity verification purposes, as well as the name, email address, and telephone number of your authorized agent.

After we verify your identity and the validity of your request, we will take the following action free of charge:

  • in the case of an access request, provide you any required personal data covering the twelve (12)-month period preceding your request; and
  • in the case of a deletion request, delete personal data that we have collected about you, subject to our right to maintain your personal data for specific purposes permitted under CCPA.

We will endeavor to comply with your verified request within forty-five (45) days, but may extend that period when reasonably necessary, in which case we will notify you.  Please note that you may only make an access request to us for your personal data up to two (2) times in any twelve (12) month period.

Privacy statement

Aprio, LLP may modify this privacy statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. This policy will be reviewed at least once a year.

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