1.  Sensory data: audio, electronic, visual, thermal, olfactory, or similar information

a. Business Purpose:

i. Audio/Visual – where required for regulatory reasons, to keep record of client instructions or other matters discussed

ii. To transcribe or prepare a written note of client meetings, interviews, etc.

b. Sources of Personal Information:

i. Conference calls and video conferences with clients and other third parties

ii. Interviews with clients as part of client scope of work or feedback program

iii. Video surveillance when visiting designated office

iv. Voicemail messages

v. Audio and/or video recordings of meetings, interviews or similar conversation designs

vi. Directly from the individual

c. Categories of Recipients May Include:

i. Our affiliates, if any

ii. Suppliers and service providers where necessary to perform functions on our behalf, if any

iii. Other parties as necessary to represent our clients, if any

2.  Identifiers and  Personal Information (PI) Categories from Cal. Civ. Code §1798.80(e) such as real name, alias, IP address, email address, account name, unique online identifier, social security number, driver’s license or state identification card number, passport number, signature, social security number, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, or other similar identifiers.

a. Business Purpose: 

i.  To preserve self-conduct in a manner that is becoming of being courteous, responsive, and collaborative and to respond to inquiries

ii.  To manage our business operations and administer our human/guest/client relationships

iii.  To provide relevant marketing to you or your employer

iv.  To address compliance and legal obligations (e.g. checking identity of new clients, prevention of fraud/money laundering, to protect the security of our networks, devices, and information)

v.  Mandatory disclosures and legal claims (e.g. to comply with any verifiable legal process or to comply  with any regulatory governmental or legally binding request)

b. Sources of Personal Information:

i.   Directly from the individual

ii.   Our affiliates

iii.  Counterparties to transactions or disputes

iv.  Individuals / Employers (i.e. clients)

v.   Agents or professional advisors authorized to disclose data on behalf of the individual

vi.  Publicly available or subscription-based sources

c.  Categories of Recipients May Include:

i.   Our affiliates, if any

ii.   Suppliers and service providers where necessary to perform functions on our behalf, if any

iii.   Other parties as necessary to represent our human/guest/client, if any

3.  Commercial Information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

a.   Business Purpose

i.   To preserve self-conduct in a manner that is becoming of being courteous, responsive, and collaborative and to respond to inquiries

ii.   To manage our business operations and administer our human/guest/client relationships, etc.

b.  Sources of Personal Information

i.    Directly from the individual

ii.   Our affiliates, if any

iii.   Counterparties to transactions or disputes, if any

iv.   Individuals / Employers (i.e. clients), if any

v.   Agents or professional advisors authorized to disclose data on behalf of the individual, if any

vii.  Publicly available or subscription-based sources, if any

c.   Categories of Recipients May Include:

i.   Our affiliates, if any

ii.   Suppliers and service providers where necessary to perform functions on our behalf, if any

iii.  Other parties as necessary to represent our human/guest/client, if any

4.   Characteristics of Protected Classifications under California or Federal Law: Race,  national origin, philosophical or religious beliefs, marital status, familial status, age (40 years or older), race, color, ancestry, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

a.   Business Purpose

i.   Only as strictly necessary for the purposes identified above

ii.   Solely to the extent required to comply with smcclellanhrpro.com’s legal or other best practice obligations (e.g. health and safety, legal forms completion, etc.)

b.   Sources of Personal Information

i.   Directly from the individual, if any

ii.   Our affiliates, if any

iii.   Counterparties to transactions or disputes, if any

iv.   Individuals / Employers (i.e. clients), if any

v.   Agents or professional advisors authorized to disclose data on behalf of the individual, if any

vi.  Publicly available or subscription-based sources, if any

c.   Categories of Recipients May Include:

i.   Our affiliates, if any

ii.   Suppliers and service providers where necessary to perform functions on our behalf, if any

iii.  Other parties as necessary to represent our human/guest/client

5.   Inferences Drawn from any of the PI identified above

a.   Business Purpose:

i.   We may draw inferences from information that we have received (such as, we may draw inferences from evidence received from or on behalf of our human/guest/client in but not limited to scope of work or project proceedings; we may conclude that you are interested in receiving updates from us on developments in particular areas if you have attended smcclellanhrpro.com sponsored events; or we may conclude that applicable laws prohibit us from engaging with a prospective human/guest/client based on information obtain through our Know-Your-Client compliance procedures)

ii.   Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

6.   Professional or employment-related information

a.   Business Purpose:

i.   To provide relevant marketing to You (e.g. information about events or services that may be of interest)

ii.   To preserve self-conduct in a manner that is becoming of being courteous, responsive, and collaborative and to respond to inquiries

iii.  Current or past job history or performance evaluations

b.   Sources of Personal Information

i.   Directly from the individual, if any

ii.   Our affiliates, if any

iii.   Counterparties to transactions or disputes, if any

iv.   Individuals / Employers (i.e. clients), if any

v.   Agents or professional advisors authorized to disclose data on behalf of the individual, if any

vi.   Publicly available or subscription-based sources, if any

c.   Categories of Recipients May Include:

i.   Our affiliates, if any

ii.   Suppliers and service providers where necessary to perform functions on our behalf, if any

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Other Personal Information We May Collect

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The categories of Personal Information We collect, the business purposes (from the list above) for which they may be used and the categories of service providers and other third parties to which We have disclosed information may further include:

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• Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• 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

• Internet or other similar network activity:  Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

• Geolocation Data:  Physical location or movements.

• 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.

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Any examples included in a category in the list above indicate only that, depending on the services and products We provide you, We may collect some information within that category. It does not necessarily mean that We collect all information listed in a particular category for all individuals.

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Additionally, for the purposes of the California Consumer Privacy Act (CCPA), Personal Information does not include: publicly available information from government records; de-identified or aggregated consumer information; information excluded from the CCPA's scope, like 1) 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; and 2) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

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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 and an opportunity to consent.

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We shall not discriminate against You for exercising your rights.

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We shall not discriminate against You for exercising any of your privacy rights related to your Personal Information. Unless permitted by applicable law, we shall not:

• Deny You good 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.

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Our Site may provide You with links to other websites. We are not responsible for those websites and cannot control the use of information that You submit once You reach those websites, nor can we control the content of what is offered on those websites or on links from those websites.

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Automated Decision Making:  We may, in some cases, use automated processes to assist our internal teams with making decisions, if it is necessary for the performance of a contract, if it is authorized by law, or if you have provided explicit consent. We do not use fully automated decision-making technologies (i.e., automated technologies that do not require human intervention) to analyze or predict aspects concerning your personal preferences, economic situations, or behavior.

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Social Media Widgets:   Our Site may include social media features, such as the LinkedIn™ button, and widgets such as the ShareThis™ button, or interactive mini programs that run on our Site. These features may collect your IP address and which page you are visiting on our Site. They may also set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company, social media platform or third-party service, providing it.

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Interaction with Chatbots:  Our Site may currently or in the future include a chatbot feature that is facilitated by a third-party service provider. If you interact with the chatbot, it may collect and record information that you provide during your interaction – including but not limited to, Your company’s name, Your business email address, Your company’s location, Your company’s industry – and this information may be shared with the third-party service provider that facilitates the chatbot feature.

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Disclosure of Personal Information, No Sale

smclellanhrpro.com has not sold or shared Personal Information as defined or as contemplated by the California Privacy Laws in the preceding 12 months. As defined and contemplated by the California Privacy Laws, smcclellanhrpro.com does not sell or share Personal Information of minors under the age of 16.

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California Consumer Privacy Rights

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As a California Consumer, you have the following rights:

• Right to Know: California Consumers have a right to submit a verified request for information from smcclellanhrpro.com regarding the specific pieces of Personal Information smcclellanhrpro.com collects and discloses for business purposes about the consumer.

• Right to Delete: In certain circumstances, you have the right to submit a verified request we delete Personal Information. Please note that the right to request deletion is subject to certain exceptions under California Privacy Laws.

• Right to Correct Inaccurate Information: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by smcclellanhrpro.com, taking into account the nature of the personal information and the purposes of processing the personal information.

• Right to Non-Discrimination: smcclellanhrpro.com will not discriminate against California Consumers for exercising their rights under the CCPA.

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smcclellanhrpro.com does not offer financial incentives or price or service differences in exchange for the retention of a California Consumer’s Personal Information.

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How to Submit a Verifiable Request

smcclellanhrpro.com will respond to requests from California Consumers in accordance with California Privacy Laws if it can verify the identity of the individual submitting the request. California Consumers can exercise these rights by visiting this page on our website: https://www.smcclellanhrpro.com/contact.  Further, smcclellanhrpro.com uses a tiered approach for verification of California Consumers. Such that smcclellanhrpro.com will match pieces of information contained in the request with information already held by the company. Where the request involves sensitive Personal Information, more data points will be required to match information maintained by smcclellanhrpro.com.

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Please note, We may not be able to comply with your request if We are unable to confirm your identity or connect the information You submit in your request with Personal Information in Our possession. Therefore, You should include information You have previously submitted to smcclellanhrpro.com for the verification process. If We are unable to verify You, We may request additional information.

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If You have questions on how to submit a verified request, please contact https://www.smcclellanhrpro.com/contact.

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Authorized Agent

You may designate an Authorized Agent to submit a request to delete, request to correct, or a request to know on your behalf. For smcclellanhrpro.com to respond to a request from an Authorized Agent, smcclellanhrpro.com may:

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• Request a copy of the written permission granting the Authorized Agent to make such a request on your behalf;

• Request confirmation from You that your authorized the agent to make the request on your behalf; or

• Request that You directly verify your own identity

Severability Clause:

 

If any provision of this Agreement is held to be invalid, illegal, or unenforceable in any jurisdiction, that specific invalidity, illegality, or unenforceability shall be severed or reformed and does not affect the validity or enforceability of the remaining provisions or that same provision in other jurisdictions―the remaining provisions will continue in full force and effect.
 

Changes to this California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) Disclaimer

 

We reserve the right, at Our sole discretion, to modify or replace the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer at any time.  If a revision is material We will make reasonable efforts to let You know via email and/or a prominent notice on Our Site, prior to the change becoming effective to any new California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer taking effect.  What constitutes a material change will be determined at Our sole discretion.  The changes will replace the then current California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer page and We will adjust the "Last updated" date at the beginning of the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer page and update the "Last updated" date at the top of this California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer.

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You are advised to review this California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer page periodically for any changes. Changes to this California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer are effective when they are posted on this page.

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Contact Us

If you have any questions about this California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) disclaimer, You can contact us by visiting this page on our website: https://www.smcclellanhrpro.com/contact