Introduction
This California Consumer Privacy Act (“CCPA”) Privacy Notice (“CCPA Notice”) supplements the information contained in the Privacy Policy of Computer Services, Inc. (“CSI”). This CCPA Notice applies solely to all visitors, users, and others who reside in the State of California, and to information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device (“California Personal Information”). CSI provides this CCPA Notice to comply with our obligations in our capacity as a “Business” under the CCPA, as amended. Any capitalized term used in this CCPA Notice but not defined will have the meaning ascribed to it in the CCPA or our Privacy Policy, as applicable.
If you are a California resident looking to exercise your rights under the CCPA, please see the section below on Exercising Access, Correction, and Deletion Rights.
As used in this CCPA Notice, the term “California Personal Information” does not include:
- Publicly available information;
- Deidentified or aggregated consumer information; or
- Other information excluded from the CCPA’s scope, including:
- 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; and
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Driver’s Privacy Protection Act of 1994, the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act.
Sources of California Personal Information
We collect the categories of California Personal Information listed above from the following categories of sources:
- Directly from you, including when you provide information to us.
- Indirectly from you, such as when we automatically collect technical and usage information when you visit our Site or use our Services.
- Affiliated companies.
- Public and publicly available sources.
- Third party websites.
Purposes for Which We Collect and Use California Personal Information
We may use or disclose the California Personal Information listed above for the following business and commercial purposes:
- All uses described under the “How We Use and Share Information” section of our Privacy Policy.
- To conduct recruiting and candidate evaluation activities and to inform our employment decisions.
- To provide, support, personalize, and develop our Site and Services.
- To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including advertisements.
- To help ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for these purposes
- To maintain the safety, security, and integrity of our Site, other technology assets, and our Services, including the detection of security incidents.
- To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Services.
- To develop, improve, and deliver marketing and advertising.
- For internal operational uses such as research, analytics, development, audits, and security.
- For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
- To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
- For any other purpose described to you when collecting your California Personal Information before or at the time of collection.
We will not collect additional categories of California Personal Information or use the California Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sensitive California Personal Information
We do not collect or process sensitive California Personal Information for the purposes other than those allowed by the CCPA and its regulations.
Disclosure of California Personal Information
We may disclose your California Personal Information to a third party for a business purpose. When we disclose California Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the twelve months prior to the “Last reviewed” date of this Privacy Policy, we disclosed your California Personal Information with the following categories of third parties:
- Our affiliated companies.
- Our customers.
- Our vendors.
- Our service providers.
- Other third parties to protect our legal rights or comply with legal requirements.
- Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- Other third parties with your prior consent.
See CSI’s “Categories of Personal Information under the California Consumer Privacy Act” summary chart above to see the California Personal Information that has been disclosed by CSI in the twelve (12) months prior to the “Last Reviewed” date and to whom such information was disclosed for a business purpose.
Sales and Shares of California Personal Information
The CCPA defines “sale” as the transfer of personal information for monetary or other valuable consideration. Although we do not “sell” California Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of California Personal Information under California law. This may include showing you advertisements on other websites.
The following table identifies the categories of California Personal Information that we sold or shared to third parties in the 12 months preceding the Effective Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:
| Category of Personal Information |
Categories of Third Parties |
| Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology) |
Advertising networks; data analytics providers |
We sold or shared Personal Information to third parties to advance our commercial or economic interests.
CSI also notes that persons attending CSI’s Annual Customer Conference on behalf of CSI customer financial institutions and other businesses may share their own Personal Information with other attendees, including exhibitors. CSI does not request the attendees to engage in the sale of their Personal Information nor does CSI receive any consideration for the sharing.
We do not knowingly collect, sell, or share the California Personal Information of consumers under 16 years of age.
Retention of California Personal Information
We retain your California Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
Your Rights and Choices with Respect to California Personal Information
The CCPA provides California residents with the following rights regarding California Personal Information:
- The right to know what California Personal Information we have collected about you, including the categories of California Personal Information, the categories of sources from which we collected California Personal Information, the business or commercial purpose for collecting, selling or sharing California Personal Information (if applicable), the categories of third parties to whom we disclose California Personal Information (if applicable), and the specific pieces of California Personal Information we collected about you;
- The right to delete California Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate California Personal Information that we maintain about you;
- If we sell or share California Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive California Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
Exercising Access, Correction, and Deletion Rights
To exercise the access, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or an authorized agent, may make a verifiable consumer request related to your California 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:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent, which includes:
- A valid copy of a California Driver’s License
- 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 your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you. Absent a power of attorney, authorized agents shall provide a signed permission from the consumer before CSI may fulfill the request.
Making a verifiable consumer request does not require you to create an account with us.
We will only use California 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response electronically.
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 California 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 we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
Right to Opt Out of Sale or Sharing of California Personal Information
If you are a California resident, you have the right to direct us to stop selling or sharing your California Personal Information.
You may submit a request to opt out of sales or sharing through our interactive webform available by clicking here. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Other California Privacy Rights
California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@csiweb.com.
Changes to this CCPA Notice
We reserve the right to amend this CCPA Notice at our discretion and at any time. When we make changes to this CCPA Notice, we will post the updated notice to our Site and update the “Last Reviewed” date.