Effective Date: August 1, 2020
Importantly, if you are an investor in a CPCP Fund, then our investor privacy notice, such as that required by the Gramm-Leach-Bliley Act of 1999, is applicable to you and the information we may collect in the course of providing financial services to you. More information about the scope of this Notice is provided below.
Note that when we say “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.
How we collect, use, and share Personal Information
When you use our website, participate in certain CPCP-sponsored survey or assessment on behalf of one of our portfolio companies (the “Service”), or otherwise interact with us, we may collect certain Personal Information about you. We do not sell any of your Personal Information.
Categories of Personal Information we may have collected about you:
- Identifiers, which may include name, address, phone number, and e-mail address;
- Internet activity information, which may include cookies, web server logs, web beacons, and other website tracking information or user activity;
- Professional or employment-related information, which may include employment history, occupation, title, and employer information, as well as test or assessment results from your participation in the HireSelect program if you choose to provide it;
- Demographic and ethnicity information, which may include age, gender, country, and preferred language, if you choose to provide it.
The business purpose for which we may have collected your Personal Information include:
- Communicating with you;
- Responding to your requests;
- Marketing purposes;
- Organizing and conducting surveys or assessments sponsored by us on behalf of our portfolio companies;
- Enhancing our services;
- Enhancing the functionality of our website;
- Promoting systems and data security;
- Monitoring compliance with applicable non-discrimination laws; and
- Performing other business purposes.
Parties with whom your information may have been shared include:
- Third parties and service providers that perform services on our behalf; or
- Law enforcement or other third parties in connection with legal requests or as required by law.
Sources of Personal Information
The categories of sources from which we collect or receive Personal Information include: you, your device(s), CPCP portfolio companies or affiliates, third parties or services providers that provide Service to you or perform services for us on our behalf, and publicly available sources.
How you can exercise your rights provided under the CCPA
Under the CCPA, you have the following rights if you are a resident of California:
- Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
- Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
- Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
To exercise your “right to know” or your “right to request deletion,” please contact us at email@example.com.
Please note that to protect the integrity of our services and to protect your privacy interests, we will need to verify your identity before processing your request. We may need additional information to verify your identity and that your state of residence is California, if you choose to provide it. This could include: a driver’s license, permit, utility bill, magazine, subscription stub, mail, school ID card, or school record.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized to make these requests on your behalf. If you choose to have an authorized agent act on your behalf, we may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
Certain exceptions under the CCPA
As alluded to above, certain types of Personal Information are exempt from certain requirements of the CCPA. This includes:
- Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (and implementing regulations), or pursuant to the California Financial Information Privacy Act;
- Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued pursuant to the Health Insurance Portability and Accountability Act of 1996, as amended;
- Personal information collected from a job applicant, employee, owner, director, staff member, officer, or contractor when the information is used in the context of the person’s role as a job applicant, employee, owner, director, staff member, officer, or contractor; and
- Personal information about an employee, owner, director, officer, or contractor of another business that is collected in connection with providing or receiving a product or service to or from the other business.
Covered business have limited obligations, or in some cases no obligations, under the CCPA with regard to these types of personal information.
Contact for more information