Last Updated: October 12, 2021
This California Privacy Notice (“Notice”) applies to our California consumers (“California Consumers,” “you”), in addition to our Privacy Policy , to inform California Consumers of their rights under the California Consumer Privacy Act of 2018 and its implementing regulations (“CCPA”).
This Notice also applies to our collection of your Personal Information when you use our products or services or through other means, for example, during communications as part of a business relationship, including in the course of our communications with or on behalf of our clients and current, prospective, and former vendors, subcontractors, and business partners, including via telephone, email or in person calls.
1. Personal Information we Collect and Disclose
When we use the term “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.
In particular, Smithbucklin has collected and disclosed the below listed statutory category (as defined by the CCPA) of Personal Information from California Consumers and for the following purposes within the last twelve (12) months:
- Identifiers - A 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.
We obtain the preceding Personal Information from the following sources:
- Directly from you, when you submit information via Smithbucklin.
- Indirectly from you, through your interactions with the Smithbucklin Site.
We disclose the above listed categories of Personal Information to the following categories of third parties:
- Our Service Providers, who have executed privacy contracts with us and have agreed to treat your Personal Information confidentially and not sell your Personal Information.
- We collect and disclose the above listed categories of Personal Information for the business purposes stated in our Privacy Policy.
2. Sale of Personal Information
In the last 12 months, we have not knowingly sold any Personal Information of California Consumers, including no actual knowledge that we have sold the Personal Information of California Consumers under the age of 16 years old. The CCPA defines “sale” as: selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information to another business or third party for monetary or valuable consideration.
If we do sell your Personal Information we will notify you, and if you submit to us a verifiable consumer request using the contact information in Section 7 below, we will disclose to you a list containing the categories of Personal Information we sold in accordance with the CCPA’s requirements.
3. California Consumers’ Privacy Rights
California Consumers may exercise their CCPA privacy rights with respect to their Personal Information by following the instructions set forth in Section 4 of this Notice. Please note that the CCPA creates a process for us to follow when evaluating your request, and there are also some exceptions to these rights.
California Privacy Rights and Descriptions
- Right to Know/Access: You have the right to request that we disclose to you what Personal Information we collect, use, disclose, and sell about you including:
- The categories of Personal Information we have collected about California Consumers in the preceding 12 months
- The categories of sources from which the Personal Information is collected
- The business or commercial purpose for collecting or selling Personal Information
- The categories of Personal information, if any, that we disclosed for a business purpose or sold to third parties in the preceding 12 months
- The categories of third parties to whom the information was disclosed or sold.
- Right to Delete: You have the right to request we delete the Personal Information we collect about you.
- Right to Opt-Out of Sale: You have the right to opt-out of the sale of your Personal Information to third parties. Currently, we do not sell your Personal Information. If you have any questions, please reach out to us by using the contact information in Section 7.
- Right to Non-Discrimination: You have the right to not receive discriminatory treatment by us if you exercise any of the rights conferred to you by the CCPA.
4. How to Exercise Your California Consumer Rights
If you are a California Consumer and would like to exercise any of your rights listed above, please contact us using the information below.
You may also designate an authorized agent to make a request to exercise your rights on your behalf. In order to do so, you must contact us using the information below.
While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
- Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting as an authorized agent on behalf of a California Consumer, please clearly indicate this fact and indicate your authority to act on their behalf.
- Help Us Verify Your Identity: Contact us using the information in Section 7 and provide us with enough information to verify your identity. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
- Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
5. How We Respond to California Consumers’ Requests
In all cases, we will respond to your request within 10 days to confirm receipt of your request and provide you with information about how we will process your request. We will then respond substantively to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
6. Contacting the California Attorney General
The CCPA also gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or telephone: 916.210.6276.
We encourage you to reach out to us first, however, so that we may help resolve any complaints you may have.
7. Contact Us
To exercise one of your CCPA rights, to contact us with questions or concerns about this our privacy practices or this Notice, or if you would like to receive a copy of this Notice in an alternate format (e.g., printable) or another language, please reach us at:
info@smithbucklin.com
312.464.6100
Smithbucklin 330 N. Wabash Avenue, Chicago IL 60611 Attn: Michael Silverman, Chief Legal Officer