California Consumer Privacy Act (CCPA) Disclosure
Last Updated 7/23/2020
Rights for California Residents
- the right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months
- the right to request, on legitimate grounds, deletion of your personal information that we collected;
- the right to have someone you authorize make a request on your behalf; and
- the right not to be discriminated against for exercising any of these rights.
Personal Information
Categories of Personal Information
- Interest rates are going down
- You intend to keep your home less than 5 years
- Characteristics of protected classifications: date of birth/age; gender; military or veteran status; marital status; nationality; citizenship; request for family care leave; request for leave for employee’s own serious health condition; request for pregnancy leave
- Biometric information: fingerprint; voice recordings; keystroke patterns and rhythms
- Professional or Employment: title; salary; employment files; references
- Education information: details of your education and qualifications
- Financial details: bank account numbers; debit/credit card numbers; cardholder or accountholder name and details; transaction details
- Commercial Information: records of personal property; products and service purchased, obtained or considered; purchasing or consuming histories or tendencies
- Internet or other electronic network activity information: browsing history, search history, information regarding your interaction with a website, application or advertisement
- Geolocation data: any information used to identify your physical location
- Communications, recordings, images: audio, electronic, visual
- Inferences: Any derivation of information, data, assumptions, or conclusions drawn from any of the above categories used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Personal Information
Category of Sources from which we Collect Personal Information
- We obtain your personal information when you provide it to us (e.g., where you contact us via email or telephone, website, or by any other means)
- We collect personal information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible)
- We receive your personal information from third parties who provide it to us (e.g., our customers; credit reference agencies; and law enforcement authorities)
- We collect or obtain personal information when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data
Use of Information
Business and Commercial Purposes for Use of Personal Information
Marketing/Prospecting
Communicating with you via any means (including via email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate
Operation of our Sites
Operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites
IT operations
Management of our communications systems; operation of IT security; and IT security audits
Health and safety
Health and safety assessments and record keeping; and compliance with related legal obligations
Financial management
sales; finance; corporate audit; and vendor management
Research
Sales; finance; corporate audit; and vendor management
Security
Physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems)
Investigations
Detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law
Legal compliance
Compliance with our legal and regulatory obligations under applicable law
Legal proceedings
Establishing, exercising and defending legal rights
Improving our products and services
Identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services
Risk Management
Audit, compliance, controls and other risk management
Fraud prevention
Detecting, preventing and investigating fraud
Disclosure of Information
Categories of Third Parties to Whom Personal Information is Disclosed
- You and, where appropriate, your family, your associates and your representatives
- Anti-fraud services
- Accountants, auditors, financial advisors, lawyers and other outside professional advisors to 220 Group, LLC, subject to confidentiality
- We collect or obtain personal information when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data
- Data aggregation services
- Accreditation bodies
- Third party service providers (such as payment services providers; shipping companies; etc.)
- Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
- Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties
- Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)

