Notice of Consumers’ Rights Under the California Consumer Privacy Act of 2018

Last modified: February 7, 2020

The California Consumer Privacy Act of 2018 as amended and including regulations promulgated by the Attorney General (the “CCPA”) grants various rights to California consumers. Because we collect personal information about you, if you are a California consumer as defined in the CCPA then this notice applies to you.

Your Rights

1. Up to two times in each 12 month period, you have the right to request that we disclose (i) the categories of personal information we have collected about you, (ii) the business purpose for collecting the information, (iii) the categories of third parties with whom we share the information, and (iv) the specific pieces of information we have collected in the past 12 months. You may exercise this right by sending an email to ccparequest@holidaytouch.com or by calling 1-800-370-8331. Only you or your authorized agent may make a request. We may require you or your authorized agent provide us with sufficient information to verify the request. You have the right to receive this information from us within 45 days of the day you make a verifiable request. If we cannot fulfill your request within 45 days, we will notify you of the reason why within that time and that we need an additional 45 days.

2. You have the right to request that we delete your information from our records and to direct any service providers to delete your information from their records. However, we are not required to, and will not delete your information that we need to (i) complete a transaction with you or provide a good or service you requested or reasonably anticipated within the context of our ongoing business relationship with you, (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity, (iii) debug to identify and repair errors that impair existing intended functionality, (iv) exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right protected by law, (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 pf Part 2 of the Penal Code, (vi) 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 our deletion of the information is likely to render impossible or severely impair the achievement of such research, if you have provided informed consent, (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us, (viii) to comply with a legal obligation, or (ix) otherwise use the information internally, in a lawful manner that is compatible with the context in which you provided the information. You may exercise this right by sending an email to ccparequest@holidaytouch.com or by calling 1-800-370-8331. Only you or your authorized agent may make a request. We may require you or your authorized agent provide us with sufficient information to verify the request.

Note for our employees and job applicants: If the only information we have about you pertains to your employment with us or application for employment with us, then you do not enjoy the rights listed above under the CCPA. However, the rest of this notice related to the categories and business purpose of this information we collect may apply to you.

We do not sell your information and therefore the obligations of businesses that sell California consumers’ personal information do not apply to us.

The Categories of, and Business Purpose for, Information We Collect

The following table shows the various categories of personal information described by the CCPA, whether we collect that category of information about any California consumers, and if so, the business purpose for which we collect it.

Please take note that under the CCPA personal information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.

Categories of Sources of Personal Information

We collect the personal information of California consumers from:

1. Directly from the consumers when they give us information over the phone, in person, or by interacting with our website;

2. Indirectly by interacting with our customers and their agents;

3. Third parties who provide us with information we use to sell and market our services.

4. Third parties we use to verify the credit and criminal background history of our customers after any such customer has consented to our commission of credit and background reports.

Non-Discrimination

We will not discriminate against you because you exercised any of your rights under the CCPA including but not limited to, by:

1. Denying you access to our services;

2. Charging different prices for our services, including through discounts, other benefits, or penalties;

3. Providing a different level or quality of services; and

4. Suggesting that you will receive a different price or different level of services.

 Privacy Policy Supplement – CCPA Supplement – v02/07/2020