California Consumer Privacy Act Notice
Under the CCPA, Personal Information is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident and includes certain categories of Personal Information and Sensitive Personal Information (a subset of Personal Information) as detailed below. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural, organizational safeguards, and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
Categories of Personal Information We Collect, Use and Disclose
In the past 12 months, we have collected and disclosed for our business purposes each of, the following categories of Personal Information relating to California residents covered by this Notice:
- 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;
- 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, date of birth, 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;
- Characteristics of protected classifications under California or federal law, which could include a person’s race, ethnicity, sex and marital status, among others;
- Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Biometric information such as fingerprints;
- Internet or other electronic network activity information, such as browsing history, search history and information regarding an interaction with an internet website, application, or advertisement;
- Geolocation data such as device location and Internet Protocol (IP) location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employers;
- Inferences drawn from any of the Personal Information listed above to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and
- The following categories of Sensitive Personal Information comprised of Personal Information that may reveal:
- Social Security, driver's license, state identification card, or passport number;
- Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- Precise geolocation;
- Racial or ethnic origin, religious or philosophical beliefs, or union membership;
- The contents of mail, email, and text messages unless the business is the intended recipient of the communication;
- The processing of biometric information for the purpose of uniquely identifying a person; and
- Personal Information collected and analyzed concerning health.
In addition to collecting a California resident’s Personal Information ourselves, we coordinate with third parties to collect Personal Information on our behalf for one or more of the business practices described below:
- Delivering advertising and marketing, including on non-affiliated persons' or entities' sites and mobile apps;
- Facilitating events and event management, including virtual and/or in-person events (e.g., hotels, restaurants, virtual platforms, audio/visual capabilities, food/beverage, transportation services, etc.); and
- Referral sources, whether for purposes of identifying candidates for employment, identifying new client opportunities, or recommending vendors or contractors.
The categories of sources from which we collect a California resident’s Personal Information are:
- Directly from a person or individuals acting on their behalf including other persons, entities, or institutions;
- Service Providers, Consumer Data Resellers, Credit Reporting Agencies, and other similar persons or entities;
- Third-party verification services;
- From activity on websites including online banking and mobile applications;
- Public Record Sources (Federal, State or Local Government Sources);
- Job applications submitted to us; and
- Information from Corporate Clients about individuals associated with the Clients (e.g., an employee or board member).
With respect to each category of a California resident’s Personal Information that we disclosed for a business purpose in the past 12 months, the categories of persons or entities to whom we disclosed that Personal Information are:
- Service Providers and Contractors who provide services such as data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing, marketing research activities, credit financing, event management, employment background checks, and real estate management;
- Other Service Providers and Contractors who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, real estate expertise, appraisal expertise, notaries and auditors;
- Other Service Providers and Contractors who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, vehicle loan processes and aggregators (at the direction of the customer);
- Government Agencies as required by laws and regulations; and
- Other persons or entities with which you may use or direct us to intentionally interact or to which you may use or direct us to intentionally disclose your Personal Information.
We collect, use and disclose for our business purposes Personal Information, including Sensitive Personal Information, relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business or commercial purposes including the following:
- Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services (except for cross-context behavioral advertising, a type of targeted advertising), providing analytic services, facilitating event management and execution, managing our real estate portfolio, or providing similar services;
- Helping to ensure security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for these purposes;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a current interaction with us, where the information is not disclosed to a third party and is not used to build a profile or otherwise alter the experience outside the current interaction with us;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance that service;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undertaking internal research for technological development and demonstration; and
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).
Retention of Personal Information
The length of time that we intend to retain each category of Personal Information will depend on a number of criteria, including (i) the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements, (ii) the length of time we may need to retain Personal Information in order to accomplish the business or commercial purpose(s) for which such Personal Information is collected, used or disclosed (as indicated in this Notice), and (iii) whether you choose to exercise your right, subject to certain exceptions, to request deletion of your Personal Information.
Sale or Sharing of Personal Information
In the past 12 months preceding the date of this notice, we have not “sold” or “shared” Personal Information or Sensitive Personal Information of a California resident subject to the CCPA nor have we “sold” or “shared” Personal Information or Sensitive Personal Information for minors under 16 years of age. For the purposes of this Notice:
- “sold” means the disclosure of Personal Information or Sensitive Personal Information to a third-party for monetary or other valuable consideration; and
- “shared” means the disclosure of Personal Information or Sensitive Personal Information to a third party for cross-context behavioral advertising.
Use of Sensitive Personal Information
We only use or disclose a California Resident’s Sensitive Personal Information for the following purposes consistent with CCPA Regulations:
- To perform the services or provide the goods reasonably expected by an average person who requests those goods or services. For example, the precise geolocation may be used by a mobile application that is providing a person with directions on how to get to a specific location;
- To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal Information, provided that the use of Personal Information is reasonably necessary and proportionate for this purpose. For example, we may disclose account information to a data security company that is hired to investigate and remediate a data incident that involved that individual's account;
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of Personal Information is reasonably necessary and proportionate for this purpose. For example, we may use information about ethnicity and/or the contents of email messages to investigate claims of racial discrimination;
- To ensure the physical safety of natural persons, provided that the use of Personal Information is reasonably necessary and proportionate for this purpose. For example, we may disclose account information to law enforcement, when required by law, to investigate financial elder abuse;
- For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a current interaction with us;
- To perform services such as maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying information, processing payments, providing financing, analytic services, or storage; and
- To verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us.
Rights Under the CCPA
If you are a California resident covered by the CCPA, you have the right to:
- Receive this Notice at or before the point of collection of your Personal Information;
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- The categories of Personal Information about you that we collected;
- The categories of sources from which the Personal Information was collected;
- The purpose for collecting Personal Information about you;
- The categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that were disclosed (if applicable) and the purpose for disclosing the Personal Information about you;
- The specific pieces of Personal Information we collected about you;
- Request we correct inaccurate Personal Information that we maintain about you;
- Request we delete Personal Information collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA.
Please see the section below entitled “How to Submit a Request,” for instructions explaining how you can exercise these rights described above. We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.
For individuals submitting a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom the request is made. For a company or organization submitting a request on behalf of another person, we may require proof of authorization from the individual such as a Power of Attorney and verification of identity directly from the person for whom the request is made.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.
For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA requests. As a result, in some instances, we may decline all or part of a request related to Personal Data exempt from CCPA requests. As another example, we will not delete Personal Data when it is necessary to maintain that Personal Data to comply with a legal obligation.
We will advise you in our response if we are not able to honor your request. We will not provide Social Security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, unique biometric data, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security. We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
How to Submit a Request
If you are a California resident, you may submit a request by:
- Writing to us at: 121 W. Pine St, Lodi, CA 95240
- Calling (800) 888-1498, M-F, 8am-6pm, PT
You may contact us with questions or concerns about this notice and our practices by calling (800) 888-1498, M-F, 8am-6pm, PT or by visiting your local branch.
Changes to This Notice
We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new revision date.