CCPA Privacy Statement – Your California Privacy Choices

Last reviewed and updated 01-10-2024.

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Collective Solution and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to 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”), as amended from time to time. Any terms defined in the CCPA have the same meaning when used in this notice.

1. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

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Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, address, telephone number, insurance policy number, or credit card number. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law. (for job applicants only)	Race, ancestry, national Origin, Sexual orientation, Gender identity and expression, Sex, Pregnancy, childbirth & related medical conditions, Religion, Disability, Age (for persons 40 and older), Military or veteran status.	YES
D. Commercial information.	Records of personal property products or services purchased, obtained, or considered.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information. (for job applicants only)	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information. (for job applicants only)	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive Personal Information	Social security number, driver’s license, state identification card, or passport number; financial account login information, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless the business is the intended recipient of the communication; genetic	NO

Personal information does not include:

Publicly available information from government records.
De-identified information, meaning information that cannot reasonably be used to infer information about, or otherwise be linked to you; or
Aggregated consumer information, such as statistical or demographic information. Aggregated information could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our websites and services.

If we combine or connect publicly available information, de-identified information, or aggregated information with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Notice.

2. Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Direct interactions. For example, from documents that you provide to us via email, in person communication, related to the services for which you engage us. We may also receive information from job applicants who directly communicate with us through our job listings page.
Indirect Collection. For example, through information we collect from our clients in the course of providing services to them.
From activity on our website (collectivesolution.net). For example, from submissions through our website portal or website usage details collected automatically.
From third-parties or publicly available resources. For example, analytics information to improve our services and from publicly available information provided by government agencies.

3. Reasons for Collecting Personal Information

We may collect your personal information for one or more of the following business purposes:

To provide you with the requested services. For example, if you provide us with personal information for our data validation services/fraud prevention services, we will use your personal information to check and validate your personal information to confirm your identity.
To provide you with information about our services.
To provide you with email alerts and other notices concerning our services that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For analyzing and improving our services and capabilities.
As necessary or appropriate to protect the rights, property or safety of us, our clients, or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. Use of Personal Information

In the last 12 months, the following categories of personal information may have been used for business and commercial purposes:

Category A: Identifiers
Category B: Personal Information categories listed in the California Customer Records statute.
Category C: Protected classification Information
Category D: Commercial Information
Category E: Biometric information
Category F: Internet or other similar network activity
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information
Category K: Inferences drawn from other Personal Information .

5. Sale of Personal Information

Selling your personal information means us selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, by electronically, your personal information to a third party for monetary or other valuable consideration.

We have not sold your personal information in the last 12 months.

6. Sharing Personal Information

The business and commercial purposes for which we have disclosed your personal information in the last 12 months are as follows:

Disclosing your personal information for business purposes. We have shared the following categories of personal information with our service providers for our business purposes:

Category A: Identifiers
Category B: Personal Information categories listed in the California Customer Records statute.
Category C: Protected classification Information
Category D: Commercial Information
Category E: Biometric information
Category F: Internet or other similar network activity
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information
Category K: Inferences drawn from other Personal Information

The business purposes for sharing such information with service providers include third-party service providers such as cloud storage providers, security providers, employee health services, site facilities providers. Your personal information may only be shared once you enter into a legal agreement with us, for example as an employee or client.

We may share your personal information with our business affiliates and subsidiary businesses for commercial purposes, in which case we will require those affiliates and subsidiaries to comply with the conditions stated in this privacy statement.

We may disclose your Personal Data if required to do so by law or in response to legal requests by public authorities (e.g., a court or a government agency).

We do not share your personal information for targeted advertising or cross-context behavioral advertising purposes.

7. Retention Criteria for Personal Information

We will retain your personal information as reasonably necessary for the disclosed purpose. The retention periods for each category of personal information vary depending on compliance with relevant laws, your request for deletion, and our retention policies. For example, we may need to retain your personal information to comply with our legal or reporting obligations in accordance with the laws or to defend against claims. Consequently, it is not possible for us to provide a definitive length of time. Our retention periods are determined by using and balancing the following criteria:

The volume, nature, and sensitivity of your information;
The potential risk of unauthorized access, use or disclosure, or misappropriation;
The purposes for which we process your personal information; and
The retention obligations under applicable legal requirements

8. Cookies and Automatic Data Collection Technologies

Our website may use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized experience when you browse our website. It also allows us to improve our website by enabling us to:

Estimate our visitor traffic and usage patterns.
Store your preferences, so we may customize our website according to your individual interests.
Recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on your computer’s hard drive.
Web Beacons, Pixel Tags, Clear Gifs. Our website pages and emails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity.

For information about managing browser settings to refuse cookies and web beacons, you can review your Internet browser settings, under “Internet Options,” to exercise choices you have for certain cookies. Please note that disabling or deleting certain cookies in your settings, may cause certain features of our website to not function properly.

9. 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.

a) 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, 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 or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Correction Rights

You have the right to request us to correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Once we receive a verifiable consumer request, we will process your 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 verifiable consumer request, 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 providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products 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 another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.

Opt-out right

You have the right to opt-out from us selling your personal information or sharing your personal information for targeted advertising. However, we do not sell or disclose personal information with third parties that would be considered a “sale” under the CCPA. We do share your personal information for targeted advertising or cross-context behavioral advertising.

b) 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 877.999.9284.
Request data by completing our Data Request Form
Emailing us at dpo@collectivesolution.net

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, 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 or an authorized representative.
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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

c) Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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.

10. 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.
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.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

11. Notice of Financial Incentives

We do not offer financial incentives or pricing discounts for providing your personal information or registering an account with us.

12. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. We have indicated the last review date at the top of this policy and update the date whenever there is a change.

13. Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices, and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 877.999.9284

Website: https://www.collectivesolution.net/

Email: dpo@collectivesolution.net

Postal Address:

Collective Solution

1901 Avenue of the Stars

Suite 200

Mailbox 0018

Los Angeles, CA 90067