Privacy Notice for California Residents
Modified: 17 May 2021
- Information we collected about you during the last 12 months:
- When you use our Website we may process the personal information which you voluntarily provide to us (e.g. by means of our contact form, first name, last name, job title, email, telephone number, address, company etc.);
- Use of Your Personal Information
We may use the personal information we collected about you for one or more of the following purposes:
- When you choose to contact, the personal information you provide to us (e.g. name, email address, correspondence) will be processed for the purpose of answering your questions, fulfilling your requests or otherwise communicating with you for direct advertising or other forms of marketing or advertising;
- When you choose to contact us in order to apply for job opportunities, the personal information you provide to us (e.g. name, contact data, application letter, CV data, photograph, certificates and references, etc.) will be processed for the purpose of reviewing your application and considering it in the recruitment process;
- If we collected your personal information from the following third-party sources: (i) third parties who license, sell or otherwise provide data they have collected; or (ii) information from publicly available sources, such as via the Internet and social networks, including through public or licensed APIs, we may use your personal information for the purpose of direct advertising or other forms of marketing, advertising or prospecting.
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 Your Personal Information
We may disclose your personal information to a third party for a business purpose. In such case, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we may have disclosed the above-mentioned personal information we collected about you for a business purpose to the following categories of persons:
- our employees;
- subsidiary companies, where necessary in order to perform our services;
- IT service providers who provide hosting, maintenance and security services for our Website;
- Schools and Administrators;
- to any other person upon your consent if necessary;
- where disclosure is required (i) by law or regulation or (ii) to establish, exercise or defend legal claims, we may also disclose your personal information to a competent authority, such as supervisory, regulatory or criminal authorities, courts of law or other third parties who advise us in this context (e.g. lawyers or forensics experts).
In the preceding twelve (12) months, we have not sold any personal information.
- Your Rights and Choices
The CCPA provides you (California residents) with specific rights regarding your personal information. This section 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 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.
- 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 Request 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 and affiliates 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 providers to:
- Complete the transaction for which we collected the personal information, provide a 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, ensure 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 seq.);
- 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.
- Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by submitting the request form annexed hereto as “Addendum A” or contacting us at 609-452-0990.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 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 the verifiable consumer request’s receipt. 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 usable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
We will not discriminate against you for exercising any of your CCPA rights.
- Changes to Our Privacy Notice
ISS reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.