Last Updated: December 19, 2019
This Privacy Notice Supplement for California Residents Only (this “Supplement”) supplements the Privacy Notice of Round Hill Partners (collectively, “Round Hill”, “we”, “us” or “our”), and applies solely to individuals who reside in the State of California (such individuals, “Consumers” or “you”). This Supplement addresses your rights under the California Consumer Privacy Act of 2018 (“CCPA”). This Supplement does not apply to individuals who are not residents of the State of California.
Please note that the CCPA does not govern the following data. Therefore, this Supplement does not apply to any such data:
- Medical information governed by the Confidentiality of Medical Information Act (Part 2.6 (commencing with Section 56) of Division 1) or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 and the Health Information Technology for Economic and Clinical Health Act.
- A provider of health care governed by the Confidentiality of Medical Information Act (Part 2.6 (commencing with Section 56) of Division 1) or a covered entity governed by the privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996, to the extent the provider or covered entity maintains patient information in the same manner as medical information or protected health information.
- Information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, pursuant to good clinical practice guidelines issued by the International Council for Harmonisation or pursuant to human subject protection requirements of the United States Food and Drug Administration.
I. Personal Information We Collect and Use
The CCPA defines “personal information” as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The table below states whether or not we have collected the following categories of such “personal information” from consumers within the last twelve months:
|Category||Examples||Collected?||If Collected, Business or Commercial Purpose for Collection|
|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||(A) it is necessary for our legitimate interests; (B) we need to comply with legal or regulatory obligations; and (C) performance of any contract we are about to enter into or have entered into with you.|
|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.||Yes||(A) it is necessary for our legitimate interests; (B) we need to comply with legal or regulatory obligations; and (C) performance of any contract we are about to enter into or have entered into with you..|
|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).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||(A) it is necessary for our legitimate interests; (B) we need to comply with legal or regulatory obligations; and (C) performance of any contract we are about to enter into or have entered into with you.|
|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||(A) it is necessary for our legitimate interests; and (B) we need to comply with legal or regulatory obligations.|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes||(A) it is necessary for our legitimate interests; and (B) performance of any contract we are about to enter into or have entered into with you.|
|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.||Yes||(A) it is necessary for our legitimate interests; and (B) performance of any contract we are about to enter into or have entered into with you.|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||No|
We obtain the categories of personal information from the following categories of sources:
- Directly from you.
- Indirectly from you (for example, from observing your actions on our Website).
- From our clients.
II. Collection and Use of Personal Information
We may collect and use the personal information we collect about you for the following purposes:
A. Using Our Website and Providing Services to You
We collect and use personal information that you submit to us during your use of our services or our Website. In addition, we may contact you to request feedback about our services in the form of online or postal communications. We use your feedback to monitor the quality of our services.
B. Insight and Analysis
We analyze your personal information that we collect from your interactions with our Website, our communications to you, and in connection with our services. The data we collect and analyze may include IP addresses; session ID information, information regarding your personal or professional interests, demographics, your experience with our services, and your contact preferences. By collecting and analyzing this data, we seek to measure the effectiveness of our content and how visitors use our Website and use our services. We also use this information for marketing purposes.
C. Protecting Our Rights and Responding to Legal Requests
We may collect or use your personal information without your consent if we believe in good faith that such action is necessary (i) to protect and defend the rights, property or safety of us or our employees, affiliates, or the public; or (ii) to satisfy any applicable law, regulation, legal process, court order, subpoena, or other governmental or regulatory (including law enforcement) request.
D. For Purposes Directed By Our Clients
When you provide your personal information to our clients, our clients may share that personal information with us. We may collect or use your personal information for the particular purposes that our clients have directed. For example, our clients may provide personal information about you to us in connection with a particular conference or other event that we host.
E. Job Recruitment
We may collect or use your personal information to assess your suitability for any position of employment for which you may apply with us. Such data may include education history, employment history and professional designations, information regarding your work authorization status, and other information about your background and qualifications.
You may communicate with us or apply for a job with us via a third party service (e.g., LinkedIn or Indeed) or via recruiting firms or staffing firms. In these instances, such third parties will share your personal information with us.
F. Business Transactions
We may collect or use your personal information 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.
G. Other Purposes
In addition to the above, we may collect or use your personal information for other purposes for which either we or our client(s) will provide notice to you at the time of collection, or as otherwise permitted under the CCPA or other applicable law.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated or incompatible purposes without providing you notice.
III. Sharing of Personal Information for a Business Purpose
We share your personal information with third parties when it is necessary for a business purpose. When we share personal information to third parties for a business purpose, we require that the recipient not further collect, sell or use such personal information except as necessary for the business purpose.
We share your personal information with the following categories of third parties: (a) our service providers, (b) our clients, and (c) third parties to whom we need to share your personal information to prepare for and conduct our events (such parties include airlines, hotels, travel agents and other parties that assist with travel and meeting logistics).
During the preceding twelve months, we have shared the following categories of personal information to third parties for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category J: Non-public education information.
IV. “Selling” Personal Information
During the preceding twelve months, we have not “sold” personal information (as the term “sell” is defined in the CCPA).
V. Your Rights Under the CCPA
The CCPA provides California residents with certain rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
A. Requests to Know
Through a verifiable consumer request, you may request disclosure of:
- Specific pieces of personal information that we have about you.
- Categories of personal information that we have collected about you.
- Categories of sources from which the personal information is collected.
- Categories of personal information that we “sold” or disclosed for a business purpose about you.
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose.
- The business or commercial purpose for collecting or selling personal information.
You may only submit a “request to know” up to twice within a 12-month period.
B. Requests to Delete
Through a verifiable consumer request, you may request that we delete your personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm such a verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Nevertheless, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete a 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.
- Debug 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.).
- Enable 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 it has been provided to us.
C. Submitting Your Requests to Know and Requests to Delete
To submit a request to know or a request to delete to us, you must submit a “verifiable consumer request” (as defined below) to us by writing us at the mailing address below, calling us at the toll-free number below, or sending an email to the email address below.
Round Hill Partners
1055 Washington Boulevard
Stamford, Connecticut 06901
Attn: Marisa Duvoisin
Toll-Free Telephone Number: 1-800-705-5361
Under the CCPA, a “verifiable consumer request” means a request that is made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a natural person or a person registered with the Secretary of State, authorized by the consumer to act on the consumer’s behalf, and that we can reasonably verify, to be the consumer about whom we have collected personal information.
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 an authorized representative. Specifically, you must provide the following information with your request:
- Your full legal name, and
- Your date of birth.
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may make a verifiable consumer request on behalf of your minor child. 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. To verify your identity or authority to make the request, we may match data points you provide with your request, with data points that we maintain.
If you choose to use an authorized agent to submit a request to know or a request to delete to us, we will require that you (i) provide us with a copy of the written permission you gave the authorized agent to submit the request to us; and (ii) verify your own identity directly with us. We may deny a request from an agent that does not submit proof that such agent has been authorized by you to act on your behalf.
If you submit a request in a manner that is not one of the designated methods of submission described above, or if your request is deficient in some manner unrelated to the verification process, we will either: (i) treat the request as if it had been submitted in accordance with our designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, if applicable.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
D. Response Timing and Format
Upon receiving a verifiable consumer request, we will confirm receipt of it within 10 days and provide information about whether and how we will process the request.
We will deliver our written response either by mail or electronically. We will endeavor to respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.
Any information we deliver in response to your request may be delivered by mail or electronically. If it is provided electronically, we will take reasonable steps to provide that the information will be portable and, to the extent technically feasible, in a readily useable format that would allow you to transmit the information to another entity without hindrance.
Any disclosures we provide will only cover the 12-month period preceding the date we received the verifiable consumer request.
We do not charge a fee to process or respond to your verifiable consumer request unless the verifiable consumer request is excessive, repetitive, or manifestly unfounded. If we determine that the verifiable consumer 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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
VII. Changes to This Supplement
We reserve the right to amend this Supplement at our discretion and at any time. When we make changes to this Supplement, we will post the updated notice on the Website and update the Supplement’s effective date. Your continued use of our services and our Website after the posting of changes constitutes your acceptance of such changes.
VIII. Contact Information
If you have any questions or concerns regarding this Supplement, please contact us at:
Round Hill Partners
1055 Washington Boulevard
Stamford, Connecticut 06901
Toll-Free Telephone Number: +1 (800) 705-5361
Telephone: +1 (203) 252-5623
Contact person: Marisa Duvoisin