UPDATED: May 7, 2020
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Routine Information Collection
All web servers track basic information about their visitors. This information includes, but is not limited to, IP addresses, browser details, timestamps and referring pages. None of this information can personally identify specific visitors to this site. The information is tracked for routine administration and maintenance purposes.
Cookies and Web Beacons
Controlling Your Privacy
Note that you can change your browser settings to disable cookies if you have privacy concerns. Disabling cookies for all sites is not recommended as it may interfere with your use of some sites. The best option is to disable or enable cookies on a per-site basis. Consult your browser documentation for instructions on how to block cookies and other tracking mechanisms.
Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices, we offer California residents regarding our handling of their personal information (the “Notice”).
CCPA Scope and Exclusions
The description in this Notice of our Privacy Practices and your Privacy Rights apply only to California residents whose interactions with us are limited to:
- Visiting our consumer websites,
- Signing up for email alerts,
- Commenting on or contributing to our blogs,
- Establishing an account that does not include financial products or services, or
- Applying for our job openings on our websites (however, note that the CCPA does not extend Privacy Rights to job applicants).
The description in this Notice of our Privacy Practices and CCPA Privacy Rights do not apply to the personal information we collect, use, or disclose about:
- Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”), or
- Representatives of businesses that seek to obtain our products or services, or to provide products or services to us.
Through our services – for example, by opening an account or initiating an application for services – you direct us to disclose your information to companies that provide the services in which you are interested.
Please note that we may also disclose all personal information (a) to comply with federal, state, or local laws; (b) to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) to cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
The CCPA grants individuals the following rights:
- Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months.
- Access. You can request a copy of the personal information that we maintain about you.
- Deletion. You can ask us to delete the personal information that we collect or maintain about you.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we can associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request
To request access to or deletion of personal information, contact us.
Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We will ask you to verify your identity when you submit a request.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.