California Consumer Privacy Act
Updated June 10, 2020
Your California Privacy Rights
This document supplements the information contained in our Privacy Notice and applies solely to California Consumers, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).
If you are a resident of California and would like to exercise your right to request access to the personal information collected about you by Abacus Insights, or would like to request that your personal information be deleted, as outlined in the California Consumer Privacy Act (CCPA), you may initiate the process by contacting us at firstname.lastname@example.org or by writing to the Privacy Officer, Abacus Insights, 40 Broad St, Boston, MA 02109. We will review your request and respond appropriately within 45 days.
Please note that Abacus Insights does not and will not sell your information as such terms are defined in the CCPA.
Information We Collect, Use, and Disclose.
Abacus Insights collects, uses, and discloses Personal Information about California Consumers for business purposes only, and which are consistent with applicable laws. Where Abacus Insights discloses Personal Information to third parties, it requires that they only use the personal information for the business purposes described below. It also requires that such parties maintain the personal information’s confidentiality, and that appropriate systems and processes are in place to ensure its security. Abacus Insights does not and will not sell your Personal Information.
We collect, use, and where indicated, disclose the following categories of Personal Information:
|Categories||Identifiers, such as your full name, title, function home address, email address, phone numbers||The information we need to deliver our services to you or respond to your inquiry||Cookie identifiers; internet protocol addresses and IP address of your electronic devices||Professional or employment related information|
|Is the data used for auditing / compliance purposes?||Yes||Yes||Yes||Yes|
|Is the data used for security Incidents management?||Yes||Yes||Yes||Yes|
|Is the data used to perform the services?||Yes||Yes||Yes||Yes|
|Is the data used for debugging purposes?||No||No||Yes||No|
|Is the data used for short-term, transient use?||No||No||Yes||No|
|Is the data used for internal research for technological development?||Yes||Yes||Yes||Yes|
|Is the data used for quality or safety purposes?||Yes||Yes||No||No|
|Service providers with whom the data is shared:||Employment sourcing and processing, and communications service providers||Communications service providers||Incident management support companies||Employment sourcing and processing, and communications service providers|
|Source of the data:||Consumer||Consumer||Consumer, third party tracking service providers||Consumer, third party enrichment service providers|
Note, under the CCPA, 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);
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and Driver’s Privacy Protection Act of 1994.
Additional Purposes for Using Personal Information.
In addition to the uses set forth above, Abacus Insights may use and share the categories of Personal Information identified:
- To comply with applicable legal and regulatory requests and obligations (including investigations).
- To establish or defend legal claims and allegations.
- For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, or other misconduct.
- To seek advice from lawyers, auditors and other professional advisers.
Your Rights and Choices.
In certain circumstances, in addition to the information provided above about the collection, use, and disclosure of Personal Information, the CCPA provides California Consumers with the following rights regarding their Personal Information:
Access to Specific Pieces of Personal Information
You have the right to request the specific pieces of personal information we (and any third parties which are Service Providers to Abacus Insights) have collected about you over the past 12 months.
Request for Deletion of Personal Information
You have the right to request that we (and any third parties which are Service Providers to Abacus Insights) delete your Personal Information, subject to certain exceptions. These exceptions include:
- Completing the transaction for which we collected the personal information, providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities;
- Debugging products to identify and repair errors that impair existing intended functionality;
- Exercising free speech, ensuring the right of another consumer to exercise their free speech rights, or exercising another right provided for by law;
- Complying with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Engaging in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enabling solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Complying with a legal obligation;
- Making other internal or lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Access and Deletion Rights.
To exercise the rights described above, please submit a verifiable consumer request via e-mail at email@example.com, or by writing to the Privacy Officer, Abacus Insights, 40 Broad St, Boston, MA 02109. Note, that under the CCPA, you may only make such a request twice within a 12 month period. Abacus Insights will respond appropriately within the required timeframes of the CCPA.
When you exercise these rights and submit a request to us, we will verify your identity by potentially requesting further information. We also may use a third party verification provider to verify your identity.
We will not discriminate against you for exercising your rights under the CCPA. 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 of quality of goods or services.
We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued interaction with Abacus Insights following the posting of changes constitutes your acceptance of such changes.
If you have questions concerning this notice, or to request this notice in another format, please contact us via e-mail at firstname.lastname@example.org, or by writing to the Privacy Officer, Abacus Insights, 40 Broad St, Boston, MA 02109.
This notice was last updated June 10, 2020.