Hill, Farrer & Burrill LLP is a limited liability partnership registered under the laws of the State of California.
Nothing stated in this notice is intended to, nor will it, establish a client-attorney relationship with persons reading it. Information provided to us in the course of any attorney-client relationship enjoys a special status and may be protected by confidentiality, the attorney-client privilege, the attorney work product doctrine and other similar protections (whether in the United States or elsewhere). Nothing in this notice detracts from any of the protections that attach to such information.
This California Privacy Notice is for California residents. As required in the California Consumer Privacy Act of 2018 (the “CCPA”), this policy describes the rights available to California consumers (defined as California residents) regarding their personal information, and our practices regarding the collection, use, disclosure, and sale of personal information. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA.
“Personal Information” for the purposes of this Notice is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you. Pursuant to the CCPA, personal information does not include the following:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope such as:
- 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;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Your Rights as A California Resident
- Right to Know and Access: This is your right to submit a verifiable request for information regarding the: (1) categories of personal information collected or disclosed by the Firm; (2) purposes for which categories of personal information are collected by the Firm; (3) categories of sources from which the Firm collects personal information; and (4) specific pieces of personal information the Firm has collected about you during the past twelve months. This right is subject to certain limitations under the CCPA;
- Right to Delete: This is your right to request that we delete the personal information we have collected from you and maintain in our systems, subject to certain exceptions that permit us to keep your personal information for specific purposes;
- Right to Non-Discrimination: This right means that the Firm will not discriminate against you in any manner because you elect to exercise any of your rights under the CCPA.
Categories of Personal Information We Collect under the CCPA
In the last twelve (12) months, the Firm has collected the following not all-inclusive categories and examples of personal information, as defined in the CCPA, about California consumers:
- Personal identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers);
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy 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);
- Protected classification characteristics under California or federal law (e.g., 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);
- Commercial information (e.g., records of personal property, services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Internet or other similar network activity (e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement);
- Geolocation data (e.g., physical location or movements); and
- Inferences drawn from other personal information (e.g., profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
Sources from Whom We Collect Personal Information under the CCPA
We collect personal information about you from a variety of sources in order to provide you with our services, communicate with you, and when you interact with us through electronic means, such as our call centers and/or Firm in-person locations, or use our services, websites and applications. These sources include:
- Information you provide to us directly, such as when you contact or communicate with us, or when you establish a customer or user account;
- Information we collect automatically and through your use of our services, websites and applications;
- Information obtained from third parties; and
- Publicly available information about you.
How We Use the Categories of Personal Information We Collect under the CCPA
We use the personal information we collect about you to provide you with reliable, high quality services, communicate with you, make improvements to our services, investigate theft, fraud and other illegal activities, and to personalize your experience. We may use the information we collect about consumers, and the circumstances under which we may share or disclose that information may include to:
- provide, deliver, maintain and improve the services you request, interact with, and to which you may subscribe;
- fulfill requests for new service or changes to your account or the services you already receive;
- provide you with technical support and high-quality customer service;
- create and administer a Firm account, including activating your service, billing, invoicing, and debt collection activities;
- authenticate or otherwise provide you access to Firm services;
- provide updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services;
- manage and configure our device(s), system(s) and network(s);
- understand how the service is being used, including through the creation of operational and marketing reports based on deidentified and/or aggregated service usage information;
- inform you of additional services that may be of interest to you;
- protect the security of the system, prevent fraud, detect unauthorized reception, use, and abuse of any Firm service, website or application, and to enforce any Spectrum policy or applicable terms of service;
- protect our rights, our personnel, our property, and the safety of others;
- maintain our accounting, tax and other records;
- comply with applicable federal and state laws and regulations, as well as for the general administration of our business;
- deliver and personalize communications with you;
- create internal business and marketing reports; and
- provide advertising and marketing subject to the applicable consent.
How You Can Submit A Request for Deletion of Your Personal Information
To protect your information, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We will use reasonable efforts to verify your identity, as well as the identity of your authorized agent to ensure that your agent has been properly authorized by you to request information on your behalf.
If we cannot verify your identity or your authorized agent’s identity, we cannot fulfill your request.
To exercise one or more of your CCPA rights, please submit a request by:
- Emailing us at email@example.com or
- Telephoning us at 213-620-0460
How You Can Opt-Out of the Sale of Personal Information to Third Parties
We do not sell your personal information to third parties for monetary consideration for any purpose, including advertising, but the Firm may disclose or make available the personal information identified earlier in this policy for limited reasons.
Your Right to Non-Discrimination
The CCPA prohibits businesses from discriminating against California consumers for exercising any of their rights under the CCPA. We will not discriminate against you for exercising any of these rights.
How we Protect Children’s Privacy
We do not knowingly collect personal information from anyone under the age of 16.
To exercise your rights under the CCPA, or if you have any questions, comments, or concerns about this policy, please contact Olga Chrysostomides, Director of Human Resources at firstname.lastname@example.org or 213-620-0460.