Effective Date: January 21, 2020
Last Revised: January 8, 2020
We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. For more information on CCPA, please visit https://oag.ca.gov/privacy/ccpa. Any terms defined in the CCPA shall have the same meaning as used in this Policy. You can also find a copy of this Policy on our website at https://www.icsecurity.com/california-privacy-policy/.
2. INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Specifically, we 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 described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||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.||YES|
|(C) Protected classifications under California or federal law.||Age, 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.||YES|
|(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.||YES|
|(F) Internet or other electronic network activity information.||Browsing history, search history, and information regarding a consumer’s interaction with an internet 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, performance evaluations, or professional affiliations and certifications.||YES|
|(J) Non-public education information per the Family Educational Rights and Privacy Act (20 U.S.C. § 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.||YES|
|(K) Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal Information does not include:
- publicly available information from government records;
- deidentified or aggregate consumer information;
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), California Confidentiality of Medical Information Act (“CMIA”), or Health Information Technology for Economic and Clinical Health Act (“HITECH”);
- 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; and
- other information beyond the scope of the CCPA.
Until January 1, 2021, or as otherwise amended by law, the CCPA will not apply to Personal Information collected by a business about a natural person:
- in an employment context or other business-related function;
- for use within the context of having an emergency contact on file; and
- to administer benefits arising from an employment context.
Until January 1, 2021, or as otherwise amended by law, the CCPA also will not apply to Personal Information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is acting in an employment context or business-related function. The communication or transaction with the business is exempt when it occurs solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from, the business.
4. HOW WE COLLECT
We obtain the categories of Personal Information listed above from the following categories of sources:
- directly from our current, former, and prospective employees (e.g., from onboarding and offboarding processes);
- indirectly from our current, former, and prospective employees (e.g., from performance evaluations and conducting our primary business function as a provider of security services);
- directly from our clients or their agents (e.g., from documents that our clients provide to us related to the services for which they engage us);
- indirectly from our clients or their agents (e.g., through information we collect from our clients in the course of providing services to them);
- directly and indirectly from activity on our website (www.icsecurity.com) (e.g., from submissions through our website portal or website usage details collected automatically); and
- from third parties that interact with us in connection with the services we perform (e.g., global positioning system information from mobile applications or devices).
5. 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 for which the information is provided (e.g., if you provide us with Personal Information to determine your eligibility for employment, we will use that Personal Information to confirm your eligibility and submit it to the appropriate governmental 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 carry out our obligations and enforce our rights arising from any contracts entered into between you and us (e.g., billing, collections, pay, benefits, etc.);
- to improve our website and present its contents to you;
- for testing, research, analysis, and product development;
- 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; or
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all 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.
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.
6. DISCLOSURE OF PERSONAL INFORMATION
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
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 H: Sensory data;
- Category I: Professional or employment-related information;
- Category J: Non-public education information; and
- Category K: Inferences drawn from other Personal Information.
We have disclosed your Personal Information for a business purpose to the following categories of third parties:
- our affiliates;
- our clients or their agents;
- service providers; and
- third parties to whom you or your agents authorize us to disclose your Personal Information.
7. SELLING OF PERSONAL INFORMATION
In the preceding twelve (12) months, we have not sold any Personal Information.
8. YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
a. Access to Specific Information
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 twelve (12) months. Once we receive and confirm your Verifiable Consumer Request (“VCR”), 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 selling that Personal Information;
- the categories of third parties with whom we share that Personal Information; and
- the specific pieces of Personal Information we collected about you.
If we sold or disclosed your Personal Information for a business purpose, we will provide two (2) separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
b. 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 (“VCR”), 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 good 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;
- debut 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 et 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, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation; and
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9. EXERCISING YOUR RIGHTS
To exercise your rights described Paragraph 8 above, please submit a Verifiable Consumer Request (“VCR”) to us by:
- calling us toll-free at +1 (800) 439-5550;
- visiting https://www.icsecurity.com/; or
- emailing firstname.lastname@example.org.
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 (“VCR”) related to your Personal Information. You may also make a Verifiable Consumer Request (“VCR”) on behalf of your minor child. You may only make a Verifiable Consumer Request (“VCR”) for access or data portability twice within a 12-month period. The Verifiable Consumer Request (“VCR”) must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- 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 (“VCR”) does not require you to create an account with us. We will only use Personal Information provided in a Verifiable Consumer Request (“VCR”) to verify the requestor’s identity or authority to make the request.
10. RESPONSE TIMING AND FORMAT
We endeavor to confirm receipt of a Verifiable Consumer Request (“VCR”) within ten (10) days of its receipt and respond to a Verifiable Consumer Request (“VCR”) within 45 days of its receipt. If we require more time (up to 90 days from receipt), 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 receipt of the Verifiable Consumer Request (“VCR”). The response we provide will also explain the reasons we cannot comply with a request, if applicable. For personal information 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 goods 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; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
12. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
13. CONTACT INFORMATION
If you have any questions or comments about this notice, our Policy, the ways in which we collect and use your personal information, your voices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: