Privacy Notice for California Residents

Effective Date: 8/9/2022

Last Reviewed on: 12/15/2023

This Privacy Notice for California Residents supplements the information contained in Schaffer Partners Inc. (“Company” or “We”)'s GENERAL PRIVACY NOTICE and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Definitions

Any capitalized terms not defined herein shall have the meaning ascribed to them in the Company Terms of Use, the Company Privacy Policy or any applicable Agreement between You and Company. Additionally, the following definitions apply in this Annex.

(a) “CCPA” means the California Consumer Privacy Act of 2018, as amended (Cal. Civ. Code §§ 1798.100 to 1798.199), and any related regulations or guidance provided by the California Attorney General. Terms defined in the CCPA, including personal information and business purposes, carry the same meaning in this Annex.

(b) “Contracted Business Purposes” means the services described in the General Privacy Notice for which the Company receives or accesses personal information.

(c) “Authorized Persons” means the persons or categories of persons that Subscriber authorizes to provide the Company with personal information processing instructions.

 

Information We Collect

Our Website collects 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 consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified 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) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, our Website does collect and has collected the following categories of personal information (“Categories”) from its consumers within the last twelve (12) months:

 

Category	Examples
A. Identifiers.	A real name, alias, postal address, online identifier such as a username, Internet Protocol (IP) address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, Social Security number, address, telephone number, passport number, driver's license or state identification card number, employment, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age, veteran or military status
D. Commercial information.	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with this Website
F. Professional or employment-related information.	Current employment information, including job title, department, and store location.

1. Company’s Use and Sharing of Your Information

(a) Company will only collect, use, retain, or disclose personal information for the Contracted Business Purposes for which you provide or permit the collection of personal information.

(b) Company will not collect, use, retain, disclose, or otherwise make personal information available for Company’s own commercial purposes or in a way that does not comply with the CCPA. If a law requires the Company to disclose personal information for a purpose unrelated to the Contracted Business Purpose, the Company will first inform you of the legal requirement and give you an opportunity to object or challenge the requirement, unless the law prohibits such notice.

(c) Company will limit personal information collection, use, retention, and disclosure to activities reasonably necessary and proportionate to achieve the Contracted Business Purposes or another compatible operational purpose.

(d) Company does not and will not “sell” your information as that term is defined in the CCPA. Company is a service provider to your employer or your Employer’s Agent under a Program.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our Business Purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list disclosing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested under a Program, 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 800-255-2639.
• Emailing us at cs@spihq.com.
• Visiting the Website and making a request through your account.

Only you may make a verifiable consumer request related to your 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 personal information, such as employer name and store location, if you have previously provided us with such information. If you make your request through your account, such a request is sufficiently verified, although you are not required to set up an account to make a request.
• 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use 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 (up to 45 more days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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 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 provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services for which you are eligible under a Program.
• Provide you a different level or quality of goods or services for any goods or services for which you are eligible under a Program.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website 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 cs@spihq.com or write us at: Schaffer Partners Inc., Customer Service, 6545 Carnegie Avenue, Cleveland OH 44103-4695

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through the Program. It is our policy to post any changes we make to our privacy policy on this page and update the "Effective Date" posted at the top of the Policy. Any changes to the Policy will become effective when the revised Policy is posted on the Website, relevant Application or other Schaffer Partners Inc. online interface, as applicable. Your continued use of our Website following the posting of changes constitutes your acknowledgement of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Schaffer Partners, Inc. collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: