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Effective: January 1, 2020
1. Personal Information We Collect
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the particular service, product or functionality if that information is necessary to provide you with such service, product or functionality or if we are legally required to collect it.
Generally, we may collect and disclose the categories of Personal Information in the table below. Please note, the examples of Personal Information are for informational purposes only and any reference to a specific type of Personal Information is not a representation that we actually collect that specific type of Personal Information. Additionally, the categories identified below cover all categories of Personal Information that we collect, use and disclose. Thus, some categories of Personal Information may not be collected from or about a specific individual.
Category with Examples
A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers.
2. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport 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.
Note: Some personal information included in this category may overlap with other categories.
3. 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).
4. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies
5. Professional or employment-related information
Current or past job history or performance evaluations.
6. Non-public education information (per the Family Education 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.
7. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Personal Information does not include:
2. How We Collect Personal Information
3. How We Use Personal Information
Griffis 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.
4. How We Share Personal Information
We share your Personal Information with the following categories of third parties:
5. Disclosures of Personal Information for a Business Purpose
In the past 12 months, Griffis has disclosed the following categories of Personal Information for a business purpose:
6. Sales of Personal Information
In the past 12 months, Griffis has not sold Personal Information.
7. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Griffis disclose certain information to you about our collection and use of Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will disclose to you, based on what you request:
Deletion Request Rights
You have the right to request that Griffis delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
How to Exercise Your Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request to exercise your access, data portability and/or deletion rights 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.
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 prior to the date we receive the verifiable consumer request. The response we provide will also provide 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.
Personal Information Sales Opt-Out and Opt-In Rights
At this time, Griffis does not sell any Personal Information. The CCPA does grant consumers rights with respect to the sale of their Personal Information. If you are 16 years of age or older, you have the right to direct companies not to sell your Personal Information at any time. If you are between 13 and 16 years of age, your Personal Information can only be sold by companies that you provide affirmatively authorize to sell your Personal Information. If you are less than 13 years of age, your Personal Information can only be sold by companies that your parent or legal guardian affirmatively authorizes to sell your Personal Information. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California Civil Code Section 1798.83, you have the right to request us to disclose the identity of any third parties to whom we have disclosed Personal Information within the previous calendar year, along with the type of Personal Information we disclosed, for the third parties’ direct marketing purposes. Please note that we are only required to respond to a customer request once during any calendar year, and only if we are covered by such California Civil Code section. If you are a California resident and would like to make such a request, contact us at firstname.lastname@example.org . Please be aware that not all information sharing is covered by this California law and only information sharing that is covered will be included in our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
We welcome your questions, comments and concerns about privacy. Please contact us at email@example.com with your feedback pertaining to privacy.