WOODRUFF SAWYER PRIVACY POLICY FOR CALIFORNIA RESIDENTS

Last Updated: January 1, 2024

This Privacy Policy for California Residents supplements the information contained in Woodruff-Sawyer’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and as amended and effective January 1, 2023, the California Privacy Rights Act (CPRA). Any terms defined in the CCPA and CPRA have the same meaning when used in this Policy. The CCPA and CPRA are collectively referred to as the “CCPA” for purposes of this Notice.

For information collected from our California-based employees, job applicants, contractors, or similar individuals. please see the section at the end of this Notice entitled “CCPA Notice at Collection for California Employees and Applicants”.

Information We Collect

We collect information from individuals 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:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope that may be covered by additional laws and regulations 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), clinical trial data, or other qualifying research data;
    • 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.]

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
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, financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 YES
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. 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. 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. 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
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. Behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.

YES

(for the purposes of personalizing services or communication)

Highly Sensitive Information

Certain of the categories listed above represent “Highly Sensitive Information” as such term is defined in the CPRA. We do not collect, use, share or store Highly Sensitive Information except for purposes of performing our services, providing our products or for such purposes as requested by you. For example, we may collect Highly Sensitive Information such as financial information for purposes of a transaction involving our products or services. We may also use Highly Sensitive Information to conduct background checks or for other purposes authorized by yourself. We do not share Highly Sensitive Information with third parties unless they are necessary to assist us in performing the services requested. For example, we may share Highly Sensitive Information with payment processors to conduct transactions or with third-party vendors who assist us with performing background checks if required. We do not sell Highly Sensitive Information to any third-parties. We also may collect Highly Sensitive Information in an employment context if you are applying for a position with our company or are currently or formerly employed by our company. For more information regarding our Highly Sensitive Information in an employment context please see below “CCPA Notice at Collection for California Employees and Applicants”.

Retention Periods for Highly Sensitive Information

Pursuant to the requirements of the CPRA [Specifically, Cal. Civ. Code § 1798.100(a)(3)], we would like to inform you that we will only keep personal information and Highly Sensitive Information for so long as it is reasonably necessary to do so in accordance with the provisions of the CPRA and our internal policies. If you are concerned regarding our retention of your personal information including Highly Sensitive Information you may request deletion of such information in accordance with the provisions of this Notice in the manner set forth below. We may be required by law to retain certain information including your personal information and Highly Sensitive Information in accordance with applicable laws requiring us to maintain such information or for a legitimate business purpose to maintain such information including but not limited to prevent fraud or to enforce our policies.

B2B Information

We currently collect certain business to business (B2B) information from vendors, customers, service providers and suppliers in order to conduct our business. This information usually includes e-mail addresses, business addresses, phone numbers, tax information such as EIN and may include Highly Sensitive Information such as financial bank information such as account numbers. We do not share this information with third-parties except to perform services or transactions requested by our B2B contacts.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or services you purchase from us.
  • Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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 about our Website users and consumers 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.

Sharing Personal Information

We may share your personal information by disclosing it to a third party, such as insurance providers, 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. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Category Category of Third-Party Recipients
Business Purpose Disclosures Sales
A: Identifiers.  Service providers, contractors. None.
B: California Customer Records personal information categories.  Service providers, contractors. None.
C: Protected classification characteristics under California or federal law.  Service providers, contractors. None.
D: Commercial information.  Service providers, contractors. None.
E: Biometric information. None. None.
F: Internet or other similar network activity. Service providers, contractors. None.
G: Geolocation data. None. None.
H: Sensory data. None. None.
I: Professional or employment-related information. Service providers, contractors. None.
J: Non-public education information. None. None.
K: Inferences drawn from other personal information. Service providers, contractors. None.

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.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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.
  • If we sold or disclosed your personal information for a business purpose, two 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.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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 Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please provide written confirmation of your authority to act on behalf of the California resident on whose behalf you are making a request.

You may also make a request to know or delete on behalf of your child by sending us an email at privacy@woodruffsawyer.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
    • Sending a copy of your government issued ID (such as a driver’s license or passport ID).
  • 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.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 our receipt of your request. 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, specifically we will provide the files in a secured zip drive via email.

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.

Personal Information Sales Opt-Out and Opt-In Rights

In certain circumstances our use of Cookies may be deemed to be a ‘sale’ under California law.  You have the right to opt-out of our ‘sale’ of your internet collected data when you browse our website.  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

CLICK HERE to select “Do Not Sell My Personal Information"

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by sending us an email requesting to opt back in.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We do not currently provide any financial incentives.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@woodruffsawyer.com or write us at: Woodruff-Sawyer & Co., Attn: Privacy Officer, 50 California Street, Floor 12, San Francisco, CA 94111.

CCPA Notice at Collection for California Employees and Applicants

We collect and uses Personal Information for human resources, employment, benefits administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of Personal Information we collect and the purposes for which we intend to use this information:

  • Identifying information, such as your full name, gender, date of birth, and signature.
  • Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
  • Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
  • Dependent’s or other individual’s information, such as their full name, address, date of birth, and Social Security numbers (SSN).
  • National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
  • Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
  • Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
  • Financial information, such as banking details, tax information, payroll information, and withholdings.
  • Health and Safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
  • Information Systems (IS) information, such as your search history, browsing history, login information, and IP addresses on the Company’s information systems and networks.
  • Sensory or surveillance information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
  • Profile or summary about an applicant/employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

The Company collects Personal Information to use or disclose as appropriate to:

  • Comply with all applicable laws and regulations.
  • Recruit and evaluate job applicants and candidates for employment.
    Conduct background checks.
  • Manage your employment relationship with us, including for:
    • onboarding processes;
    • timekeeping, payroll, and expense report administration;
    • employee benefits administration;
    • employee training and development requirements;
    • the creation, maintenance, and security of your online employee accounts;
    • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
    • workers’ compensation claims management;
    • employee job performance, including goals and performance reviews,
      promotions, discipline, and termination; and
    • other human resources purposes.
  • Manage and monitor employee access to company facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of Company policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of the Company.
  • Maintain commercial insurance policies and coverages, including for workers’
    compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Administer and maintain the Company’s operations, including for safety purposes.
  • For client marketing purposes.
  • Exercise or defend the legal rights of the Company and its employees.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Woodruff-Sawyer collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (877) 334-5140

Website: www.woodruffsawyer.com

Email: privacy@woodruffsawyer.com

Postal Address:
Woodruff-Sawyer & Co.
Attn: Privacy Officer
50 California Street, Floor 12, San Francisco, CA 94111

If you need to access this Policy in an alternative format due to having a disability, please contact us at privacy@woodruffsawyer.com.