This Notice describes the rights of consumers under the California Consumer Privacy Act of 2018 (“CCPA”). Creative Family Connections LLC (the “Company”) respects your privacy. Your California Privacy Rights Notice (“California Privacy Notice”) applies solely to individual visitors, users, registrants, and others who are residents of the State of California (“consumers” or “you”).
Information Company Collects:
The Company collects 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:
In particular, the Company may have collected the following categories of Personal Information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card 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.
Some Personal Information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, 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).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. 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.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. 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.||NO|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
The Company obtains the above categories of Personal Information from the following categories of sources:
Information Company Uses:
The Company may use or disclose the Personal Information Company collects for one or more of the following purposes:
The Company will not collect additional categories of Personal Information or use the Personal Information that the Company has collected for materially different, unrelated, or incompatible purposes without providing you notice.
Information Company Shares:
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
We do not sell Personal Information. In the preceding twelve (12) months, Company has not sold Personal Information. For this reason, we are not required to provide the “Do Not Sell My Personal Rights” Notice.
|Personal Information Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|A: Identifiers.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|B: California Customer Records personal information categories.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|C: Protected classification characteristics under California or federal law.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|D: Commercial information.||None.||None.|
|E: Biometric information.||None.||None.|
|F: Internet or other similar network activity.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|G: Geolocation data.||None.||None.|
|H: Sensory data.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|I: Professional or employment-related information.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
|J: Non-public education information.||None.||None.|
|K: Inferences drawn from other personal information.||Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.||None.|
Your Rights and Choices:
The CCPA provides consumers with specific rights regarding their Personal Information. This Section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability Rights:
You have the right to request that the Company disclose certain information to you about Company’s collection and use of your Personal Information over the past 12 months (the “Right to Know”). Once the Company receives and confirm your verifiable consumer request, the Company will disclose to you:
Right to Delete:
You have the right to request that Company delete any of your Personal Information that Company collected from you and retained, subject to certain exceptions (the “Right to Delete”). Once Company receives and confirms your verifiable consumer request, Company will delete (and direct Company’s service providers to delete) your Personal Information from Company’s records, unless an exception applies.
Company may deny your deletion request if retaining the information is necessary for Company or Company’s service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Right to Know, Data Portability Rights, and Right to Delete:
To exercise your Right to Know, Data Portability Rights, and Right to Delete as described above, please submit a verifiable consumer request to Company at:
Via Email: firstname.lastname@example.org
Via Mail: Creative Family Connections, 2 Wisconsin Circle Suite 700, Chevy Chase, MD 20815
Only you, or someone legally authorized 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:
Company cannot respond to your request or provide you with Personal Information if Company 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 Company. Company 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:
The Company will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt of such request. If the Company requires more time, the Company will inform the requestor of the reason and extension period in writing, which may be extended for up to an additional forty-five (45) days (90 days in total from the date of receipt of the verified consumer request).
If you have an account with us, the Company will deliver our written response to that account. If you do not have an account with us, the Company will deliver a written response via email, if your request is either made via email or an email address is provided in a verified consumer request that is mailed; provided however, the Company will provide a written response via regular postal mail to the address you provided in the consumer verified request if a response by mail is expressly requested in the consumer verified request.
Any disclosures the Company provides will only cover the 12-month period preceding the verifiable consumer request’s date of receipt. The response the Company provides will also explain the reasons the Company cannot comply with a request if that is the case. For data portability requests, Company 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.
The Company does not charge a fee to process or respond to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded and unreasonable. If the Company determines that a fee is warranted for your request, the Company will inform you the reasons under which the Company has warranted such fee and provide you with an estimated cost of such fee prior to completing your request.
The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not:
However, the Company may offer you certain financial incentives as part of a financial incentive program (“Program”) permitted under the CCPA that could alter the prices, rates, or quality levels of the goods or services you receive. Any CCPA-permitted Program that the Company offers will reasonably relate to your Personal Information’s value and contain written terms describing the material details of such Program. Your prior “opt in” consent, which you may revoke at any time, is required to participate in any such Program.
Other California Privacy Rights:
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits the Company’s Website users, which are California residents, to request certain information pertaining to the Company’s disclosure of Personal Information to third parties for their direct marketing purposes. Please contact Company to make such a request.
Privacy Notice Changes:
The Company reserves the right, in its sole discretion, to update, change, modify, add, or remove portions of this California Privacy Notice from time to time and without notice. No amendment, modification, extension, limitation, waiver, or termination of this California Privacy Notice by you shall be valid except with the written consent of the Company. The Company encourages you to periodically review this page for the latest information regarding the Company’s California Privacy Notice. Your continued use of the Website and other Company IP is subject to the most current effective version of Company’s California Privacy Notice. If you object to this California Privacy Notice after it becomes effective for you, you may no longer use or access the Company IP, including the Website.
If you have any questions or comments about this notice, the ways in which the Company collects and uses your Personal Information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact the Company at:
Via Email: email@example.com
Via Mail: Creative Family Connections, 2 Wisconsin Circle, Suite 700, Chevy Chase, MD 20815