PRIVACY NOTICE – CALIFORNIA CONSUMERS ONLY
Information We Collect
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:
- 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients, prospects or employees. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients, prospects or their employees. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.human-capital.com) or other portals. For example, from submissions through our website or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we provide. For example, from government agencies when we verify data associated with payroll processing and withholding tax payments.
Use of Personal Information
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To operate, manage and maintain our business.
- To accomplish our business purposes and objectives
- To communicate with 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 testing, research, analysis and service offering development.
- For vendor management purposes.
- 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.
Sharing Personal Information
WE DO NOT, AND WILL NOT, SELL YOUR PERSONAL INFORMATION. We may share your personal information within the Human Capital, LLC family of companies to provide services to you or in an effort to assess your needs and how we can help fulfill those needs.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category D: Commercial information
Category E: Biometric information
Category F: Internet or other electronic network activity information
Category G: Geolocation data
Category I: Professional or employment-related information
Category K: Inferences drawn from other personal information
We disclose your personal information for a business purpose to our affiliates and/or to one or more of the following categories of third parties:
- Third party service providers
- Administrators authorized by your organization
- Licensors or third-party applications (if you access a third-party application on our services through a license agreement with a licensor)
- Other parties where required by law or to protect our rights
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
In the preceding twelve (12) months, we have not sold any personal information to third parties within the scope of the application of the CCPA.
Your Rights and Choices
The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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 sharing that personal information
- The affiliates we shared your personal information with
- 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 to a third party for a business purpose, separate lists identifying the personal information categories that each category of recipient obtained
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 product 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.
- 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.).
- 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.
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 888.736.9071
- Emailing us at firstname.lastname@example.org
- Visiting HUMAN-CAPITAL.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 that you are an authorized representative of a person about whom we collected personal information
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
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. 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you products or services
- Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties
- Provide you a different level or quality of products or services
- Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services
How to Make a Request
You may make a request for the disclosures or deletion described above by contacting us using one of the methods described below.
You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or the California Constitution.
Changes to Our Privacy Notice
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 via:
First Class Mail, Return Receipt:
Human Capital, LLC
ATTN: Privacy Officer
1111 W Long Lake Road Ste. 104
Troy, MI 48098