Effective Date: January 1, 2023
California Consumer Privacy Act (CCPA) and California Consumer Rights Act (CPRA) Notice
Greater Tech Holdings is providing this notice to you pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act of 2020 (the “CPRA”). This notices only applies to residents of the State of California and does not apply to residents of any other states, districts, territories, or countries.
This notice details certain rights available to residents of California found in the CCPA and CPRA.
Your Rights under the CCPA and CPRA
- The right to know the information we collect about you.
- The right to know what information we share about you with third parties.
- The right to make the following requests:
- The categories of personal information we collected about you within the preceding 12 months.
- The categories of sources from which the personal information is collected.
- The business or commercial purpose for which we collected personal information.
- The categories of third parties with whom information is shared.
- The specific pieces of personal information that we have collected about you.
- The right to request the deletion of certain personal information.
- The right to non-discrimination in accessing products and services when exercising these rights.
Your Right to Know
You have the right under the CCPA and CPRA to request that we disclose to you certain personal information about you that we collect, use, disclose, share, and sell that is not subject to exemption under the CCPA and CPRA.
CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT
|A.||Identifiers.||Account Name, Address, Beneficiary Name, Beneficiary Relationship, Client ID Number, Client Reference Number, Contract Number, Date of Birth, Date of Death, Driver’s License Number, Email Address, Emergency Contact Name, Emergency Contact Number, Employee Identification Number, Name, Passport Number, Phone Number, Policy Number, Policy Rating Information|
|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.||Characteristics of protected classifications under California or federal law.||Gender, Age, Citizenship Status, Disability, Marital Status|
|D.||Commercial Information||Transaction information, purchase history, financial details, and payment information|
|E.||Professional or employment-related information.||
Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
|F.||Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Student records and directory information.|
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information or services.
- To provide you with email alerts, event registrations and other notices concerning our services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- As reasonably necessary and proportionate to protect the rights, property or safety of us, our clients or others.
- To respond to regulatory and/or 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.
- As otherwise required or permitted by law
We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Length of Retention of Personal Information
Personal Information collected is only retained for so long as is reasonably necessary for one or more of the above purposes.
Disclosing Personal Information
We may disclose your Personal Information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial Information.
Category E: Professional or employment-related information.
Category F: Professional or employment-related information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service Providers and Vendors.
- Third parties to whom you authorize us to disclose your personal information in connection with products or services we provide to you.
- To other third parties as required or permitted by law.
Selling or Sharing Personal Information
We do not “sell” or “share” your personal Information to anyone as those terms are defined in the CCPA.
Exercising Access/Data Portability, Correction, and Deletion Rights
To exercise the access, data portability, correction, opt-out, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us toll-free at 1-888-739-6001.
- Visiting: California Resident Privacy Request Page
Only you or a person registered with the California Secretary of State for which you authorize to act on your behalf, may make a verifiable consumer request related to 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 your identity or your authority to make a request on behalf of a California resident.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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. Making a verifiable consumer request does not require you to create an account with us. Personal Information provided will only be used by us to verify the requestor’s identity and/or authority to make the request.
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), we will inform you of the reason and extension period in writing. 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 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.
- Retaliate against an employee, applicant for employment, or independent contractor.