Privacy Notice and Disclosure for California Residents
What Information Do We Collect?
We collect 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: (a) information that is publicly available from government records; (b) de-identified or aggregated consumer information; or (c) information excluded from the CCPA's scope, such as (i) 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; or (ii) personal information covered by sector-specific privacy laws including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“CalFIPA”), or the Driver’s Privacy Protection Act of 1994.
|Categories of Personal Information Collected||Sources of Collection||Business/Purposes for Collection||Categories of Third Parties Receiving Personal Information|
|Personal identifiers including name, alias, signature, address, phone number, email address, social security number, device identifier, date of birth/age, driver’s license or other state ID card number or passport number||Individual customers. Third parties involved in transactions with our customers. Insurance claims and other matters. Other individuals or third parties who communicate with us. Advertising companies and content publishers that present you with our ads||To provide products and services to our customers. To communicate with individuals who interact with us and our partners. To provide registration for client or firm events. To provide technical support to our customers. To make informed business decisions for marketing campaigns, product development, and new features. To verify customer requests and comply with applicable laws and regulations.||Third parties involved in transactions or litigation with our clients. Marketing service providers. Third parties involved in verifying customer requests or other compliance activities|
|Financial information including bank account numbers or other financial information||Individual clients||To collect payment for our services. To facilitate payments and transactions||Debt servicing and collection agencies. Third party payment processors|
|Internet and other network activity information including online identifiers such as an Internet Protocol (“IP”) address or device identifiers, browsing history, search history, user mobile device type, browsing platform, Wi-Fi connectivity and signal strength, and information about individual interactions with our website, electronic communications, or advertisements||Website visitors. Devices and platforms used to access our website||To provide information about our services online. To determine how many unique visitors our website receives, locate the approximate geographic regions of our website visitors, and identify returning visitors. To deliver marketing communications and advertising. To identify the devices used to access digital content||Website analytics providers. Marketing service providers. Technology support providers. Advertising partners. Advisors and consultants|
In the past twelve (12) months, RWC has disclosed personal information to service providers for business or commercial purposes. The categories of personal information we have disclosed to service providers for business or commercial purposes include:
- Internet and other network activity information
- Personal identifiers, such as name, title, biographical information (from other sources in the course of our business), social media identifiers, physical address, IP address, email address, or other, similar identifiers.
Aside from disclosures to service providers, the CCPA also requires that RWC disclose “sales” of personal information to third parties. The CCPA further requires businesses that “sell” personal information (as the term “sell” is defined under the CCPA) to provide an opt-out from such sales. Some people have taken the position that when a website or app uses third-party cookies and similar technology for its own analytics or advertising purposes, the website/app is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app. Some take this position even when the website/app pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party.
RWC does not believe that any of its activities with service providers constitute “sales” under the CCPA and currently available guidance. However, if you take the position that any of the relationships described above involve a “sale” within the meaning of the CCPA, then you may consider RWC to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on www.rwc.com or affiliate sites), and “commercial information” (like the fact that a browser visited a page directed to people who are considering purchasing from us) to those service providers. As we await clarity , we continue to offer opportunities to limit and/or opt out of the collection and/or use of data via certain third-party cookies and similar technology for analytics and advertising purposes, as described in the paragraph below.
You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. Some browsers offer similar settings for HTML5 local storage, and Flash storage can be managed as described here.
A. California Right to Know
California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purpose for collecting their personal information, and the categories of third parties with whom we shared their personal information. You may submit a request to know by following the process outlined in Section C below.
B. California Right to Delete
California residents have the right to request deletion of the personal information we have collected from them, subject to certain exceptions set forth within the CCPA. You may submit a request to delete by following the process outlined in Section C below.
We may deny your deletion request if we are unable to verify the request or if retaining the information is necessary for us or our service provider(s) 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 et. seq.).
- 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Except to the extent we may deny your request above, we shall otherwise make reasonably best efforts to retrieve and delete any personal information associated with or linked to you. We shall also reach out to any third party vendors with whom we may have shared your personal information to request deletion and confirmation of the same.
C. Submitting a Request
You can submit a request exercising your right to know or to delete by visiting the following link or by calling 1-844-924-0069. You will need to provide us with personal information to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purposes. We do not discriminate against California residents who exercise their privacy rights under CCPA.
Once we properly verify your request, we will send you an acknowledgement letter via email or mail describing our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
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 via email or mail why we made that decision and provide you with a cost estimate before completing your request.
Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.
Submitting Requests via an Authorized Agent: Only you, a person registered with the California Secretary of State, or a person 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures outlined above. If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.
D. Your Right to Non-Discrimination for the Exercise of a Privacy Right
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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your provided personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
E. Changes to this Policy
We may update and make changes to this Policy to reflect any changes to our information practices. If we make any material changes, we will notify you in accordance with applicable law. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review our website for the latest information on our privacy practices.