Your California Privacy Rights

Last Updated: January 1, 2020

Introduction

For California residents only. This Privacy Notice supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Categories of Personal Information Collected

Consistent with the, “Collection and Use of Personal Data” section found within our Privacy Policy, we collect certain categories and specific pieces of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

Category of Personal Information
(corresponds to categories listed in CCPA §1798.140(o)(1))
ExamplesDo we collect?Do we disclose for business purposes?Do we sell?
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
A. Identifiers.
Examples:
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.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples:
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.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
C. Protected classification characteristics under California or federal law.
Examples:
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).
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
D. Commercial information.
Examples:
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
E. Biometric information.
Examples:
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.
Do we collect?:
Yes
Do we disclose for business purposes?:
No
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
F. Internet or other similar network activity.
Examples:
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
G. Geolocation data.
Examples:
Physical location or movements.
Do we collect?:
No
Do we disclose for business purposes?:
No
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
H. Sensory data.
Examples:
Audio, electronic, visual, thermal, olfactory, or similar information.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
I. Professional or employment-related information.
Examples:
Current or past job history or performance evaluations.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
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)).
Examples:
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.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No
Category of Personal Information (corresponds to categories listed in CCPA §1798.140(o)(1)):
K. Inferences drawn from other personal information.
Examples:
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Do we collect?:
Yes
Do we disclose for business purposes?:
Yes
Do we sell?:
No

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Personal Information Sources

Sutherland obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, for employment purposes, forms you complete or to fulfill product and services requests
  • Indirectly from you. For example, from observing your actions on our Website.
  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.

 

Purposes for which Personal Information is Used

We collect your personal data for business and commercial purposes described in the, “Purpose of Use” column, found under the “Collection and Use of Personal Data” in our Privacy Policy

Personal Information Sold

Sutherland does not and has not sold any personal information in the last 12 (twelve) months.

Your Consumer Rights Under the CCPA

Under the CCPA, you may have the following consumer rights. Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA:

Abbreviated Right to Know (Collection): You have the right to request, at no charge, we disclose to you the categories and specific pieces of Personal Information Sutherland has collected in within the last twelve (12) months.

Expanded Right to Know (Collection and Disclosure): You have the right to request that we disclose certain information about how we have handled your Personal Information within the last twelve (12) months, including the:

  • categories of Personal Information collected about you;
  • categories of sources from which we collected your Personal Information;
  • business and/or commercial purposes for collecting and disclosing your Personal Information; and
  • categories of third parties to/with whom your Personal Information has been disclosed/shared, including for a business purpose; and
  • the specific pieces of Personal Information collected about you.

Access and Portability: You have the right to obtain a list of categories and a copy of the Personal Information, in a portable and (if technically feasible) readily usable format, collected on you covering the 12-month period preceding the request.

Deletion: You have the right to request the deletion of your Personal Information we have collected from you. This right may be subject to certain conditions and limitations under the law.

Right to be Free from Discrimination: You may exercise all of the above rights at all times and Sutherland will not unlawfully discriminate against you for exercising your rights under the CCPA.

Submitting a Request to Exercise Your Rights

California residents have the right to submit a request for deletion of information under certain circumstances.

Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

To exercise any of your rights as set out above, please contact us by completing the form available here or call us toll free at 1-866-I-OPT-OUT (1-866-467-8688) and enter Service Code 843.

TRUSTe

Contact Us

Sutherland Data Privacy Office

Attention. Chief Data Privacy Officer

Sutherland Global Services Inc.,

1160 Pittsford Victor Road

Pittsford, NY 14534

Email: privacy@sutherlandglobal.com