California Consumer Privacy Notice
This is Richards, Layton & Finger, P.A.’s Privacy Notice for California Residents (“Notice”) and applies to visitors, users, and others who reside in the State of California (“consumers,” or “you/your”) and use our Services. This notice is provided to Comply with the California Consumer Privacy Rights Act of 2018 and the California Privacy Rights Act (“CCPA” and “CPRA”, respectively) and any terms defined in the CCPA/CPRA have the same meaning when used in this Notice.
Scope
This California Notice applies to the Personal Information we collect, both online and offline, about California consumers, including Personal Information that we collect:
- From users of our website, including the services available via our Website;
- About clients and individuals who use or inquire about our legal and related services that we make available;
- About individuals who attend events hosted or sponsored by us, reply to our email or communications, visit our offices, or otherwise communicate or engage with us; or
- About individuals from clients and others related to the services we provide.
This California Notice does not address or apply to:
- Our handling of personal information that is exempt under Section 1798.145 of the CCPA;
- Personal information we collect about employees, contractors, or job applicants or other individuals who are not California residents; or
- Personal information we collect about individuals acting in their capacity as representatives (“B2B contacts”) of our clients, prospective clients, vendors and other businesses that we conduct business with, to the extent we use their personal information only in the context of conducting our business relationship with the respective business where the residence of the individual is not known or known to be outside of California.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, with a particular consumer or household (“Personal Information”).
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA/CPRA’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.
We collect different types of information from users, and we use and/or disclose this information for different business purposes. The chart below identifies the Personal Information we may collect and for what business purpose the information is collected. Within the last 12 months, we may have collected the following categories of personal information either directly or indirectly from you:
| Category of Personal Information | Specific Personal Information that may be collected | Purpose of Collecting the personal information |
| A. Identifiers | Name, mailing address, email address, gender, and telephone number; financial payment information; IP address | To uniquely identify an individual in support of business activities |
| B. Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)) | Name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, education, employment, employment history, bank account number or any other financial information. Some personal information included in this category may overlap with other categories | To uniquely identify an individual in support of business activities |
| C. Protected classification characteristic under California or Federal law | Age (40 years or older), national origin, citizenship, marital status, sex, veteran or military status. | To identify and evaluate candidates for employment and for workforce management purposes. |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | In connection with our provision of legal services and business operations. |
| E. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | To allow access to our Website and optimize our Website and in connection with our provision of legal services and business operations. |
| F. Geolocation Data | Physical location or movements | To manage our workforce and systems and detect security incidents and malicious activity. |
| G. Professional or employment-related information | Current or past job history or performance evaluations | To identify and evaluate candidates for employment and for workforce management purposes. |
| H. 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. | To identify and evaluate candidates for employment and for workforce management purposes. |
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information.
- To provide you with information or services that you request from us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
- To evaluate or conduct a reorganization or combination of our firm with another firm.
- For any other purpose allowed by law.
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.
Sharing Personal Information
We may disclose and have disclosed, in the past 12 months, Personal Information to third parties, service providers, and contractors for business purposes as set forth above and in this Privacy Policy, including to support our workforce management (including payroll vendors and human resources SaaS providers), website operations and security (including internet service providers, web hosting companies, and monitoring and detection services), and to support our operations (document vendors and legal support vendors), or as otherwise required by law. In the preceding twelve (12) months, we have not sold Personal Information. We do not share your Personal Information as defined under Cal. Civ. Cd. 1798.140(ah).
Data Retention
We will retain your personal information for no longer than is necessary for the purposes stated in this Notice, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario or service. The standards we use to determine the retention period are as follows:
- The time required to retain personal data to fulfill business purposes, including providing services.
- Maintaining corresponding transaction/business records.
- Controlling and improving the performance and quality of the website.
- Handling possible user queries or complaints and locating problems.
- Whether the user agrees to longer retention periods.
- Whether the law, contracts, and other equivalencies have special requirements for data retention.
Your Rights and Choices
The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes CCPA/CPRA rights and explains how to exercise those rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
The only sensitive personal information we affirmatively collect from you is necessary to perform the services you requested. We also may periodically receive unsolicited information from you that includes sensitive personal information; we make no further use or disclosure of that unsolicited information. If you have questions about sensitive personal information, please see Exercising Limitation, Access, Rectification, Data Portability, and Deletion Rights to contact us.
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 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 of the disclosures made identifying the personal information categories that each category of recipient obtained.
Correct/Rectify Personal Information
You have the right to rectify (correct, update, or modify) the personal information we collect about you. After making such a request, we will take commercially reasonable efforts to correct inaccurate personal information within 45 days of receiving the request. In the event an extension is needed, we may take an additional 45 days when reasonably necessary. In this case, we will provide you a notice of extension within the first 45-day period.
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 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.
- Help ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- 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 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, specifically if you previously provided informed consent and deleting that information may seriously impair or render impossible the research’s achievement.
- 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 personal information that are compatible with the context in which you provided it.
Exercising Limitation, Access, Rectification, Data Portability, and Deletion Rights
To exercise the limitation, access, rectification, data portability and deletion rights described above, please submit a verifiable consumer request to us by:
- Calling us at 302-651-7700
- Emailing us at privacy@rlf.com
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 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.
Response Timing and Format
We will try our best 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. 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 receipt of the verifiable consumer request. 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 and should allow you to further transmit information if you desire.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or 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/CPRA rights. Based solely on the exercise of your CCPA/CPRA rights, we will not:
- Deny you services
- Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of services
- Suggest that you may receive a different price or rate for services or a different level or quality of services
Changes to this Notice
We reserve the right to amend this CCPA/CPRA Policy at our discretion and at any time. When we make changes to this CCPA/CPRA Policy, we will notify you through a notice on our website homepage.
Contact Us
To ask questions or comment about this Notice and our privacy practice contact us at:
Richards, Layton & Finger, P.A.
privacy@rlf.com 302-651-7700