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 and Deletion Rights.
As used in this CCPA Notice, the term “California Personal Information” does not include:
- Publicly available information lawfully made available from federal, state, or local government records;
- 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
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:
As defined by the CCPA, we collect, or have collected in the past twelve (12) months, the following categories of personal information:
- Identifiers (such as name, email address, postal address, phone number, IP address).
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as name, contact information, employment).
- Commercial information (such as transaction information, purchase history, payment information).
- Internet or other electronic network activity information (such as browsing history, search history, online behavior).
- Professional or employment-related information (such as job title and your business contact information).
- Inference data about you (such as additional features we think would be of interest to you).
As a California resident, you may request the following information about how we have collected and used your Personal Information during the past 12 months (your right is not absolute and we may decline your request as permitted by the CCPA):
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient.
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 prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
- 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.
Sharing 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.
We may share and disclose 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 involved in a merger, sale, joint venture or other transaction involving a transfer of our business or assets.
- 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 of California Personal Information
In the past twelve (12) months prior to the “Last Reviewed” date of this Notice, CSI has not sold California Personal Information. CSI does not and will not sell California Personal Information. However, CSI 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 understand the attendees to engage in the sale of their Personal Information nor does CSI receive any consideration for the sharing.
Your Rights and Choices with Respect to California Personal Information
The CCPA provides California residents with specific rights regarding California Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information
You have the right to request that we disclose certain information to you about our collection and use of your California Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see the section below on Exercising Access and Deletion Rights), we will disclose to you:
- The categories of California Personal Information we collected about you.
- The categories of sources for the California Personal Information we collected about you.
- Our business or commercial purpose for collecting that California Personal Information.
- The categories of third parties with whom we share that California Personal Information.
- The specific pieces of California Personal Information we collected about you (also called a data portability request).
- If we disclosed your California Personal Information for a business purpose, we identify the California Personal Information categories we disclosed and provide you with details of the purposes for the disclosures.
Deletion Request Rights
You have the right to request that we delete any of your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will delete (and direct our service providers to delete) your California Personal Information from our records, unless an exception under CCPA applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the California Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1.833.700.6909; or
- Emailing us at our privacy request portal.
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 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 representative, 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.
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 by mail or electronically, at your option.
Any disclosures we provide in response to a request will only cover the 12-month period preceding the receipt of the request. 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.
Non-Discrimination
You have a right to not receive discriminatory treatment for exercising your CCPA rights, and we will not discriminate against you for exercising any of your CCPA rights.
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 our privacy request portal.
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org
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. Your continued use of our Site and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy and this CCPA Notice periodically for updates.
Contact Us
If you have any questions regarding this Privacy Policy or the practices of our Sites, please contact us at:
Computer Services, Inc. (CSI)
ATTN: Data Protection Officer
3901 Technology Drive
Paducah, Kentucky 42001-5201
privacy@csiweb.com
800.545.4274
Last Reviewed: May 3, 2021