Privacy Notice for California Residents

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.

California Personal Information We Collect, Use, and Disclose

In the twelve (12) months before the “Last Reviewed” date of this CCPA Notice, we have collected the following categories of California Personal Information and disclosed such information for a business purpose as detailed below:

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, Use, and Disclose California Personal Information

We collect, use, and disclose the California Personal Information listed above for the following business and commercial purposes:

• All uses described under the “How We Use Your Personal Data” 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.
• To advance our commercial or economic interests.
• For any other purpose described to you when collecting your California Personal Information before or at the time of collection.

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.

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 “Last Reviewed” Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

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 be retaliated against for exercising 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:

• Calling us at 1.833.700.6909; or
• Contacting us through our privacy request portal.

Only you, or an authorized agent, may make a verifiable consumer request related to your California Personal Information. We will comply with your request upon verification of your identity, and to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

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.

Contact Us

If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us at: