Notice of California Privacy Rights

Your Rights and Choices

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively the “CCPA”) provides California residents with specific rights regarding their personal information. In addition to our Privacy Policy, this webpage further describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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, 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.
The specific pieces of personal information we collected about you (also called a data portability request).
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.

Deletion 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, 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 provider(s) 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.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech protect 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 ).
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.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Correction Rights

You have the right to request that we correct inaccurate personal information about you. We will take into account the nature of the personal information and the purposes of the processing of the personal information in responding to your request. We will process your request if we receive a verifiable request and we will use commercially reasonable efforts to correct the inaccurate personal information as directed pursuant to the CCPA/CPRA.

Your Right to Limit the Use of Sensitive Personal Information

You have the right, at any time, to direct us to limit our use of your sensitive personal

Information only to that use which is necessary to perform the services or provide the goods reasonably expected or to fulfil the reason that we collected such information and/or other permissible business purposes. Sensitive personal information includes:

Government ID — your Social Security number, driver’s license number, state identification card number, passport number, or other official identifier.
Financial Information — your financial account log‐in credentials, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
Geolocation — your precise geolocation.
Race, religion and union membership — your racial or ethnic origin, religious or philosophical beliefs, or union membership.
Communications — the contents of your private communications, unless we are the intended recipient of the communication.
Genetics — your genetic data.
Biometrics —biometric information processed for the purpose of uniquely identifying you (such as a fingerprint or voice print).
Health — personal information collected and analyzed concerning your physical and mental health.
Sexual orientation — personal information collected and analyzed concerning your sex life or sexual orientation.

Please note that we do not use or disclose your sensitive personal information for purposes other than to provide you with our services. However, note that this information may be used, or disclosed to a service provider or contractor pursuant to a written agreement in order to provide such services. Note that this right does not apply to sensitive personal information that is collected or processed without the purpose of inferring characteristics about you.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us by either calling us at 401-251-0643, emailing us at [email protected] or contacting us through this link https://www.cckbequest.com/contact/.

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 related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
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. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to provide enough information that allows us to reasonably verify that you are the person that we collected information about. We will not require you to incur any costs or fees in order to process or provide a verifiable request.

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

Response Timing and Format

We will confirm receipt of a verifiable consumer request within ten (10) business days and provide information about how we will process the request.

We will provide a response to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to 45 calendar days), 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.

For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to provide enough information that allows us to reasonably verify that you are the person that we collected information about.

Some web browsers allow you to set a global “Do Not Track” flag that is visible to websites. We will treat these flags as valid opt-out requests under California law. However, note that these signals are associated with a specific device and will not transfer when you switch web browsers, such as from a laptop to a mobile device. Additionally, we do not keep records that match users to their web browsers or IP addresses. Therefore, you will need to submit a written request to exercise these rights as they relate to your information in our customer records.

The third-party vendors that we use to conduct this tracking may include, but are not limited to, Google Analytics, Lucky Orange and Call Tracking Metrics. These third-party vendors use cookies to collect standard internet log information and website user behavior information. The information generated by the cookie about your use of our website (including your IP address and geo-location) is transmitted to the vendors. This information is then used by the vendors to evaluate our users’ use of our website and to compile statistical reports on website activity for Chisholm Chisholm & Kilpatrick LTD only. This information will not be used for direct marketing purposes or cross-context behavioral advertising.

Therefore, while California residents have the right to opt-out of the sale of their personal information and the sharing of their personal information for cross-context behavioral advertising under the CCPA, we do not sell personal information to any third parties or share personal information for such purposes, and therefore, we have not included a “Do Not Sell or Share My Personal Information” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.Additionally, we do not intend to market to any individual under the age of 18, and we expressly prohibit, anyone under the age of 16 from disclosing or submitting any personal information to us through our Site or other means. Therefore, we do not sell or share any information of any individual under the age of 18.

NON-DISCRIMINATION/NON-RETALIATION

We will not discriminate or retaliate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you services.
Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of services.
Suggest that you may receive a different price or rate for services or a different level or quality of services.

OTHER CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83, the “Shine the Light” law, permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following: [email protected] or 401-331-6300.

Accessibility Statement

We are committed to making sure that our website is accessible to everyone. To access our Privacy Policy in an alternative form, please contact us at [email protected] or 401-331-6300 so we may provide a copy in an alternative format. For more information, please see our Accessibility Statement.