Bold, Polisner, Maddow, Nelson & Judson, A Professional Corporation
California Supplemental Privacy Notice
Effective Date: August 2024
SUMMARY OF PERSONAL INFORMATION THAT WE COLLECT ABOUT YOU
For individuals who are California residents, we have adopted this California Privacy Policy (the “CA Privacy Policy”) to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws, which require certain disclosures about the categories of personal information we collect, how we use them, the categories of sources from whom we collect personal information, and the third parties with whom we share it. This CA Privacy Policy is supplementary to the general privacy policy (“Privacy Policy”) for Bold, Polisner, Maddow, Nelson & Judson, A Professional Corporation and its subsidiaries and affiliates (collectively, the “Company”). All undefined capitalized terms used herein shall have the same meaning as set forth in the Privacy Policy. By using the Website, you consent to the collection and use of your “personal information” (as that term is defined below) as described in this CA Privacy Policy.
Depending on how you interact with the Company, we may collect certain categories of information as summarized in the table below. This CA Privacy Policy does not apply to personal information we collect from employees or job applicants in their capacity as employees or job applicants. It also does not apply to personal information we collect from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services. Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- 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.
SOURCES OF PERSONAL INFORMATION COLLECTED
All of the categories of personal information we collect about you (as detailed below) come from the following types of sources:
- From you or your representatives, including through your use of our services.
- Automatically collected from you or your representatives.
- Automatically through your or your representative’s activity on our Website.
- From third parties that interact with us in connection with the services we provide.
CATEGORIES OF PERSONAL INFORMATION COLLECTED IN THE LAST TWELVE MONTHS
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”). In particular, we have collected the following categories of personal information from consumers during the twelve (12) months prior to the Effective Date of this CA Privacy Policy:
| Category of Information | Collected? | Source | Business Purposes* for use |
| A. Identifiers (name, alias, postal address, email address, phone number, fax number, account name, Social Security number, driver’s license number, passport number, unique personal identifiers, IP address) | Yes | Individuals submitting information to us;
Information we automatically collect from site visitors;
Information we may receive from third parties such as opposing counsel. |
Auditing relating to transactions;
Security detections, protection and enforcement;
Functionality debugging/error repair;
Ad customization;
Performing services for you;
Quality control |
| B. Protected Information
(name with: Social security number, driver’s license or state ID number, financial account, medical, health, and health insurance information, user name and password) |
Yes | Individuals submitting information;
Employment applications;
Employees.. |
Performing services for you. |
| C. Protected anti-discrimination classification information (Age (40 years or older), race, gender, ethnicity) | Yes | Individuals submitting information. | Performing services for you;
Compliance with law. |
| D. Commercial information
(Transaction history, products/services purchased, obtained or considered, product preference) |
Yes | Individuals submitting information;
Information we collect through client relationships with us. |
Auditing relating to transactions;
Performing services to you;
Quality control |
| E. Electronic network activity
(browsing or search history, website interactions, advertisement interactions) |
Yes | Information automatically collected from site visitors and from employees or others with access to our systems. | Auditing related transactions;
Security detection, protections and enforcement;
Functionality debugging/error repair;
Performing services for you;
Quality control. |
| F. Audio, video or similar information (customer service calls, security monitoring) | Yes | Individuals submitting information;
Information we collect for security purposes. |
Auditing related transactions;
Security detection, protections and enforcement;
Functionality debugging/error repair;
Performing services for you;
Quality control. |
| G. Biometrics | No | Not Collected | Not Collected |
| H. Geolocation | Yes | Information we automatically collect from site visitors. | Auditing relating to transactions;
Security detection, protection and enforcement;
Functionality debugging/error repair;
Ad customization;
Performing services for you. |
| I. Professional, educational or employment related information | Yes | Information submitted by individuals;
Information received from third parties in connection with vendor or employment status or applications;
Information we observe in connection with vendor or employment oversight. |
Performing services for you;
Quality control;
Ad customization;
Compliance with law. |
| J. Non-public educational information (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 | Not collected | Not collected |
| K. Sensitive Personal Information (social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership, genetic data, biometric information, health, sex life or sexual orientation.) | Yes | Information submitted by individuals;
Information received from third parties in connection with vendor or employment status or applications;
Information we observe in connection with vendor or employment oversight. |
Identity verification;
Employment and benefit administrations;
Vendor oversight;
Security detection, protection and enforcement;
Compliance with law. |
| L. Inference from the Above
(preferences, characteristics, behavior, attitudes, abilities, etc.) |
Yes | Internal analytics | Auditing relating to transactions;
Security detection, protection and enforcement;
Functionality debugging/error repair;
Performing services for you;
Internal research and development;
Quality control |
BUSINESS/COMMERCIAL PURPOSES FOR OUR USE OF PERSONAL INFORMATION
All of the categories of personal information we collect about you (as detailed above) are used for the following purposes:
- Providing our services (for example, account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our services).
- Providing email alerts, event registrations, and other notices concerning our products or services, or other events or information that may be of interest to you.
- For our operational purposes, and the operational purposes of our service providers and integration partners.
- To enable efficient logins to our hardware and systems.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- Improving our existing services and developing new services (e.g., by conducting research to develop new services, products, or features).
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity.
- Bug detection, error reporting, and activities to maintain the quality or safety of our services.
- Auditing consumer interactions on our site (for example, measuring page views).
- Short-term, transient use, such as customizing content that we or our service providers display on the services.
- Other uses that advance our commercial or economic interests, such as communicating with you about relevant offers.
- Such other uses that we notify you about when collecting your personal information or otherwise.
YOUR RIGHTS AND CHOICES
Subject to certain restrictions, California residents have the right to request that we disclose what personal information we collect about you, to delete any personal information that we collected from or maintain about you, and to opt-out of the sale of personal information about you. As a California resident, you also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us either through our email at [email protected] or call us at (925) 933-7777.
Accessing and Deleting Your Personal Information
- Right to request access to your personal information
California residents have the right to request that we disclose what categories of personal information that we collect, use, disclose, or sell about you. You may also request the specific pieces of personal information that we have collected about you. However, we may withhold some information where the risk to you, your personal information, or our business is too great to disclose the information.
- Right to request deletion of your personal information
You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.
- How to exercise your access and deletion rights
California residents may exercise their California privacy rights by submitting your request to us either through our email at [email protected] or call us at (925) 933-7777.
For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights so we can reasonably verify you are the person about whom we collected such personal information (or that person’s authorized representative).
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and the extension period in writing. If you have an account with us, we will deliver our written response through your account. If you do not have an account with us, we will deliver our written response by mail or electronically as you so request. 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.
Once you submit a request to (1) access the categories of personal information we have about you or (2) obtain a copy of specific pieces of personal information we have about you, we will ask that you verify you identity by logging into your account using your username and password. There, we will provide you with your information in a password-protected format.
To request that we delete personal information we have collected from you, you will need to authenticate with us by first logging into your account using your user name and password on file with us and deleting your account, once you let us know you’ve taken this action we will initiate the deletion process.
If you wish to exercise any of these rights and do not have an account with us, please contact us either through our email at [email protected] or call us at (925) 933-7777 and we will request additional information to perform identity verification where possible.
Sales of Personal Information
California residents may opt out of the “sale” of their personal information. The Company does not “sell” your personal information as we understand that term to be defined by the CCPA and its implementing regulations.
Non-Discrimination Rights
California residents have the right to not be discriminated against for exercising their rights as described in this section. We will not discriminate against you for exercising your CCPA rights.
