CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This Notice does not apply to (a) certain natural persons who are job applicants, employees, owners, directors, officers, medical staff members or contractors of HSC (or any emergency contact persons to such natural persons) solely to the extent otherwise applicable Personal Information is collected in connection with such role, (b) certain communications and transactions between HSC and natural persons acting as employees, owners, directors, officers or contractors of an entity and whose communication or transaction occurs solely in the business context and (c) certain other communications, transactions and information, as set forth in the CCPA.
Information We Collect
We collect Personal Information as defined in the CCPA. Personal Information can generally be described as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We have collected and anticipate collecting the following categories of Personal Information:
- Identifiers and Personal Information categories listed in the California Customer Records statute, such as name, signature, property address, telephone number, online identifier, internet protocol address, email address, account name, bank account number, credit card number, debit card number or other financial information
- Commercial information, such as records of personal property, products or services purchased, obtained or considered
- Internet or other electronic network activity, such as web browsing history, search history or other information on your interaction with our website, application or advertisement
- Sensory data, such as recordings used to verify certain transactions
Sources of Information Collected
We collect the Personal Information listed and described above from the following categories of sources:
- Directly or indirectly from Consumers or their agents.;
- from third parties that we interact with in the course of providing products or services to Consumers.
- from third parties from whom we purchase Personal Information in order to provide a new or better service to you or prospective customers; and
- from public sources.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes:
- to allow you to purchase products or services from us;
- to permit you to maintain an account and profile with us;
- to share your Personal Information with our affiliates and subsidiaries, where we consider appropriate;
- to fulfill or meet the reason you provided the Personal Information. We may also retain your information to provide new product or service orders, promotions, contests or sweepstakes;
- to fulfill and facilitate any repair or replacement obligations owed to you in connection with any home service plan covering your property, including sending you maintenance communications;
- to provide, support, personalize, develop and improve HSC products and services, including but not limited to HSC Applications;
- to provide you with support and respond to your inquiries;
- to help maintain the safety, security and integrity of HSC products, services, databases and other technology assets, including, but not limited to the HSC Applications;
- for testing, research, analysis and product development;
- to respond to law enforcement requests and as required by applicable law, court order or governmental regulations;
- to prevent transactional fraud and other illegal activity;
- to evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other transaction
Sharing Personal Information for a Business Purpose
We share your Personal Information for a legitimate business purpose with the following categories of third parties:
- Service providers, including advertisers, data brokers or aggregators, analytics providers, direct-mailing service providers and email-marketing service providers;
- HSC’s subsidiaries and affiliates (“Affiliates”); and
- third parties to whom you or your agents instruct or authorize us to disclose your Personal Information such as real estate agents, title agents or insurers, attorneys or financial institutions
When we disclose Personal Information for a business purpose to a Service Provider, we enter into a written contract with the applicable Service Provider that (a) describes the services to be provided, (b) requires such Service Provider to keep any Personal Information we have disclosed thereunder confidential and (c) prohibits such Service Provider from using such Personal Information for any purposes except those purposes explicitly set forth in the contract.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold Personal Information. In addition, we will not sell Personal Information during any time period in which this Notice does not set forth instructions with respect to a Consumer’s “right to opt-out” of the sale of Personal Information.
Your Rights and Choices
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your rights under the CCPA 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 twelve (12) months. Once we receive and confirm your Verified Request (as defined below), we will disclose to you:
- all categories of Personal Information we have collected about you in the twelve (12) months prior to our receipt of your Verified Request;
- all categories of sources from which we have collected Personal Information about you in the twelve (12) months prior to our receipt of your Verified Request;
- our business or commercial purpose for collecting, selling or disclosing, as applicable, such Personal Information;
- the categories of third parties with whom we have shared any such Personal Information for a business purpose, organized in a list (which such list shall be separate from the list detailing the third parties to whom any such Personal Information was sold) that shows the categories of any such Personal Information we shared with each category of third party (or, if we have not shared any such Personal Information, we shall disclose the same);
- the categories of third parties to whom we have sold any such Personal Information, organized in a list (which such list shall be separate from the list detailing the third parties to whom any such Personal Information was shared for a business purpose) that shows the categories of any such Personal Information sold to each category of third party (or, if we have not sold any such Personal Information, we shall disclose the same); and
- the specific pieces of Personal Information we have collected about you (also called a data portability request) in the twelve (12) months prior to our receipt of your Verified Request.
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 Verified Request, we will remove (and direct our Service Providers to remove) such Personal Information from our records, unless an exception applies.
We may deny your deletion request to the extent that retaining the Personal Information is necessary for us or our Service Providers to:
- (i) complete the transaction for which we collected the Personal Information, (ii) provide a good or service that you requested (or that is reasonably anticipated to be requested within the context of our ongoing business relationship), or (iii) otherwise perform a contract with you;
- detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities;
- debug products or software to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise any other right provided for by applicable law;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- enable solely internal uses that are reasonably aligned with your expectations based on your business relationship with us;
- comply with a legal obligation; or
- make use of such Personal Information for other internal and lawful purposes that are compatible with the context in which you provided such Personal Information.
If it is necessary for us to retain certain information, we will inform you of the basis for such retention in response to your request. For example, as a provider of home service plans, we may retain, for internal purposes, certain information relating to the service performed on your home.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability or deletion rights described in this Notice, please submit a verifiable consumer request to us (a “Verified Request”) by emailing us at firstname.lastname@example.org or sending us a letter via certified mail at the address below.
Only you, or someone legally authorized to act on your behalf (an “Authorized Agent”), may make a Verified Request related to your Personal Information. To designate an Authorized Agent, please email us at email@example.com or write us at:
Home Service Club of California, Inc.
8910 University Center Lane, Suite 400
San Diego, CA 92122
A Verified Request must allow us to properly understand, evaluate and respond to it. In addition, your Verified Request must provide information sufficient to allow us to verify you are the Consumer about whom we collected Personal Information or an Authorized Agent of such Consumer, which such verification may include:
- California residency verification;
- verification of first name, last name, phone number, property address, contract number, phone number or email;
- re-verification through phone, email or other communication mediums (in particular, if a request to delete is made online); and
- for Authorized Agents, (a) a signed authorization from the applicable Consumer evidencing such designation and (b) verification of such Consumer’s identity in accordance with the verification methods applicable to other Consumers.
We cannot respond to a request to provide you with Personal Information if we cannot verify (a) your identity, (b) a purported agent’s identity or authority to make the request or (c) that the requested Personal Information relates to you. If we deny your Verified Request to know specific pieces of Personal Information, we will inform you and explain the basis for such denial in writing via email or regular mail.
We will only use Personal Information provided in a Verified Request to verify the requestor’s identity or authority to make the request.
In accordance with the CCPA, we are required to provide access and data portability with respect to a Consumer’s Personal Information no more than two (2) times to such Consumer in any twelve (12) month period.
Response Timing and Format
We endeavor to respond to each Verified Request within 45 days of our receipt of such Verified Request (If we require more time), we will inform you of the reason and extension period in writing. We will deliver our written response to your Verified Request by mail or electronically.
Any disclosures we provide will only cover the 12 month period preceding our receipt of the applicable Verified Request. For data portability requests, we will select a format in which 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 will not discriminate against you for exercising any of 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; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Notice
We reserve the right to amend this Notice at at any time for any reason in accordance with applicable law. When we make changes to this Notice, we will post the updated Notice on the HSC Applications. YOUR CONTINUED USE OF HSC APPLICATIONS FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE OF SUCH CHANGES.
If you have any questions or comments about this Notice, the ways in which HSC collects and uses your Personal Information or your choices and rights regarding such collection and use under California law, please do not hesitate to contact us at:
Home Service Club of California, Inc.
8910 University Center Lane, Suite 400
San Diego, CA 92122