Effective Date: January 1, 2023
Last Revised on: January 1, 2023
Last Reviewed on: January 1, 2023
This California Notice at Collection and Privacy Policy (“CCPA Disclosure”) explains how Reliance Partners, LLC and its subsidiaries and affiliates (“Reliance Partners”, “Company”, “us”, “our”, or “we”) collect, use, disclose, sell, share, and/or retain personal information (“Information Practices”) subject to the California Consumer Privacy Act (“CCPA”). This CCPA Disclosure applies solely to California residents (“consumers” or “you”).
This CCPA Disclosure does not apply to information we collect in the context of an individual’s interaction with us as a job applicant, employee, contractor, or other role within our Company. Please refer to our Workforce CCPA Disclosure.
The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used, including whether that information is sold or shared.
| Do We collect? | Categories of Personal Information | Purposes for Collection | Sold to Third Parties or Shared with Third Parties for Cross-Context Behavioral Advertising |
|---|---|---|---|
| ☒ | Identifiers: For example, a name, address, online identifier, Internet Protocol address, email address, or other similar identifiers. |
| We sell/share IP address, device type and characteristics, unique device identifiers to web analytics providers and advertising partners. |
| ☒ | Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, 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. |
| N/A |
| ☒ | Characteristics of CA or Federal Protected Classifications: age (40 and over) |
| N/A |
| ☒ | Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| N/A |
| ☒ | Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. |
| We sell/share IP address, device type and characteristics, unique device identifiers to web analytics providers, advertising partners, and data brokers. |
| ☒ | Professional or Employment-Related Information: For example, current and past compensation and employment history. |
| N/A |
We do not collect: biometric information, geolocation data, sensory or surveillance data, education information, or profile data in this policy.
| Do We collect? | Categories of Sensitive Personal Information | Purposes for Collection | Sold to or Shared with Third Parties for Cross-Context Behavioral Advertising |
|---|---|---|---|
| ☒ | Social Security Number, Driver’s License, State Identification Card, or Passport Number |
| N/A |
| ☒ | Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account |
| N/A |
We do not collect: precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; or information concerning sex life or sexual orientation.
We retain information for different periods of time depending on the purposes for which we collect and use it. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.
Our use of tracking technologies may be considered a sale or sharing with third parties for cross-contextual behavioral advertising (e.g. targeted advertising) under California law. You can opt-out of being tracked by these third parties by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our website and selecting your preferences.
To review our California Privacy Policy, please see immediately below.
The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding our Information Practices. You have certain rights to control the use of your personal information. This privacy policy describes your rights as it relates to our Information Practices as to your personal information and how you can exercise those rights.
The following table includes disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.
| Category | In the preceding 12 months this category was collected: | In the preceding 12 months this category was disclosed: | Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed |
|---|---|---|---|---|
| Identifiers | ☒ | ☒ |
|
|
| Personal Information Categories from Cal. Civ. Code § 1798.80(e) | ☒ | ☒ |
|
|
| Characteristics of CA or Federal Protected Classifications: | ☒ | ☒ |
|
|
| Commercial Information | ☒ | ☒ |
|
|
| Professional or Employment-Related Information | ☒ | ☒ |
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|
We do not collect: biometric information, geolocation data, sensory or surveillance data, education information, or profile data in this policy.
We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated under CCPA. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.
| Category | In the preceding 12 months this category was collected: | In the preceding 12 months this category was disclosed: | Business or Commercial Purpose for Collection & Disclosure | Categories of third parties to whom the information was disclosed |
|---|---|---|---|---|
| Social Security Number, Driver’s License, State Identification Card, or Passport Number | ☒ | ☒ |
|
|
| Account log-in, financial account, debit card, or credit card number when provided with any required security or access code, password, or credentials allowing access to an account |
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|
We do not collect: precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages (unless we are the intended recipient of the communication); genetic data; biometric information for the purpose of unique identification; health information; or information concerning sex life or sexual orientation.
The categories identified as collected in the tables above were collected from the following categories of sources:
We have sold or shared with third parties for cross-context behavioral advertising personal information to third parties in the preceding 12 months as disclosed in the table below. We do not sell or share any sensitive personal information.
| Categories sold to or shared with third parties over the last 12 months | Categories of third parties to whom this category of personal information has been sold or shared |
|---|---|
| Identifiers |
|
| Internet or Other Similar Network Activity |
|
The purpose of the notice of Right to Opt-Out is to inform you that you have the right to direct us to stop selling or sharing your personal information, which is called the “Right to Opt-Out.”
You may exercise your Right to Opt-Out by:
You have the right to request that we disclose any of the following:
You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
You have the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements. We may deny your request if we have previously denied your same request to correct an alleged inaccuracy in the past six (6) months, unless you provide new or additional documentation that the information at issue is inaccurate.
As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
You have the right to request that we delete any of your personal information collected by us, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, “Submitting a Verified Consumer Request.”
There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.
You have the right to submit verified consumer requests to know information, to correct information, or for deletion.
The response to a request to know will provide all personal information collected and maintained about you since January 1, 2022, unless doing so proves impossible or would involve disproportionate effort. Please note that we are not required to provide personal information to you more than twice in a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the 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.
If you have a password-protected account you may submit the request through the account by email to consumerrequests@reliancepartners.com.
If you do not have a password-protected account, you may also submit a request through our webform, which can be accessed by clicking here and providing the requested information. You can also submit requests by calling Reliance Partners at 877.668.1704 or emailing your assigned producer or account manager. If you call us or email your assigned producer or account manager, we will ask that you provide the same information that we request in the webform.
If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies.
Your request will be verified by matching the information you provide to information that we have collected. For additional questions, please call 877.668.1704.
Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.
Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.
Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. All requests must be submitted via email to your producer or account manager, or via online form. Once received the email will be verified against the primary contact on file. For additional questions, please call 877.668.1704.
Our use of tracking technologies may be considered a sale/sharing under California law. You can opt-out of being tracked by these third parties by clicking the “Do Not Sell of Share My Personal Information” link at the bottom of our website and selecting your preferences, or by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. Because the signal is browser-specific, you will need to broadcast subsequent signals if you are accessing our website through different online devices (e.g., computers, smartphones, tablets).
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
a. Deny you goods or services.
b. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
c. Provide you a different level or quality of goods or services.
d. 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 still offer you certain financial incentives permitted by the CCPA such as discounts, rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.
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 us using the form at the bottom of the page or write us at:
Reliance Partners
PO Box 11227
Chattanooga, TN 37402
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, 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.
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via email at consumerrequests@reliancepartners.com.
