Information for California Residents
 

In addition to our full Privacy Policy, this CCPA Privacy Policy applies to all California residents (“Consumers”) who are included in our searchable profiles, and all Consumers from whom we collect personal information as a business under the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”), who are not registered users of the Wall Street Connector ("WSC") platform. If you are a Consumer who is a registered user of the WSC platform, a notice concerning your privacy rights in that capacity is available here.

For the purposes of this CCPA Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.

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Personal Information does not include information that is:

• Lawfully made available from government records;

• De-identified or aggregate information; or

• Otherwise excluded from the scope of the CCPA.

Consumer does not include a natural person acting as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, or contractor of WSC to the extent such person’s Personal Information is collected within the context of the person acting in such role.

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California Consumers’ Rights and Choices

• If you are a Consumer, the CCPA may permit you to request information regarding the:

  • ​Categories of Personal Information (as defined by the CCPA) collected, sold or disclosed by us;

  • Purposes for which categories of Personal Information collected by us are used;

  • Categories of sources from which we collect Personal Information;

  • Categories of third parties with whom we share Personal Information; and

  • Specific pieces of Personal Information we have collected about you and in some cases your Household.

• In addition, if you are a Consumer, you may:

  • ​Opt out of the sale of your Personal Information, in some circumstances (please see Do Not Sell My Info page);

  • Opt out of receiving marketing communications from us; however, you may still receive administrative communications regarding our services;

  • Opt in to certain financial incentive programs we may offer related to the collection, retention, or sale of your Personal Information; and

  • Request that we and our service providers delete Personal Information we have collected from you, in some circumstances.

• Further, the CCPA provides Consumers with the right not to receive discriminatory treatment by a business for the exercise of these CCPA privacy rights, subject to certain limitations.

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Use of Personal Information

• The Personal Information may be used for the purposes disclosed to Consumers at the time of collection, in our general Privacy Policy, and for the purposes of: providing our services, developing and providing marketing materials, complying with judicial process or government requests and undertaking internal research for technological development and demonstration. The Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.

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Sale of Your Information

• You can opt out of the sale of your personal information on the Do Not Sell My Info page or or Emailing us at: connect@wallstreetconnector.com

• Please be aware that we do not accept or process opt-out of sale requests through other means (e.g., via fax or social media).

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Privacy Requests

• You can opt out of the sale of your personal information on the Do Not Sell My Info page or or Emailing us at: connect@wallstreetconnector.com

• Please be aware that we do not accept or process opt-out of sale requests through other means (e.g., via fax or social media).

• We will review the information provided and may request additional information to ensure we are interacting with the correct Consumer. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

• By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.

• We generally will aim to avoid requesting additional information from you for the purposes of verification. However, if we cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, we may consider any of the following factors, alone or in combination, in requesting additional information:

  • The type, sensitivity, and value of the Personal Information collected and maintained about the Consumer, as applicable law requires a more stringent verification process for sensitive or valuable personal information;

  • The risk of harm to the Consumer posed by any unauthorized access or deletion;

  • The likelihood that fraudulent or malicious actors would seek the Personal Information;

  • Whether the Personal Information to be provided by the Consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;

  • The manner in which we interact with the Consumer;

  • Available technology for verification; and

  • Other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this CCPA Privacy Notice.​

• We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

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Authorized Agent Requests

• You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a written authorization signed by you and the authorized agent. You may submit evidence of your designation of an authorized agent in writing to: connect@wallstreetconnector.com

• We may require verification of your authorized agent in addition to the information for verification above for Consumers.

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Notice of Financial Incentive

• We do not offer financial incentives to Consumers based upon the collection, retention or sale of a Consumer’s Personal Information.

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Shine the Light

• You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the Contact US section below.

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Contact Us

• If you have any questions or concerns regarding this CCPA Privacy Policy, email us at connect@wallstreetconnector.com

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Last updated: October 1, 2021