This California Privacy Policy (the "Policy") supplements the Online Privacy Policies of Headlands Technologies LLC ("HT") and Headlands Tech Global Markets, LLC ("HTGM") and their affiliates (collectively, "we," "us," or "our") and applies solely to users, visitors, business partners, employees, candidates, and others who reside in the State of California ("consumers" or "you"). This Policy has been adopted to comply with the California Consumer Privacy Act of 2018 (the "CCPA") and other California Privacy laws. Any terms defined in the CCPA have the same meaning when used in this Policy.
We collect information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category | Title | Examples | Collected |
---|---|---|---|
A |
Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
YES |
B |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) |
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. *Note that some information in this category may overlap with other categories. |
YES |
C |
Characteristics of protected classifications under California or federal law |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
YES |
D |
Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
E |
Biometric information |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
F |
Internet or other similar network activity |
Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. |
YES |
G |
Geolocation data |
Physical location or movements. |
YES |
H |
Sensory data |
Audio, electronic, visual, thermal, olfactory, or similar information. |
NO |
I |
Professional or employment-related information |
Current or past employment history, performance evaluations, or professional references. |
YES |
J |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99) |
Records, files, documents, and other materials which contain information directly related to a student and are maintained by an educational agency or institution or by a person acting for such agency or institution. |
NO |
K |
Inferences drawn from other personal information |
Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
NO |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
We do not and will not knowingly collect, disclose, or sell data relating to children, that is, individuals under the age of 16 years.
We may use or disclose the personal information we collect for one or more of the following business purposes:
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.
We may disclose your personal information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
We do not and will not sell any personal information. In the preceding twelve (12) months, we have not sold any personal information.
The CCPA grants consumers (i.e., California residents) certain rights regarding their personal information. This section describes your rights under the CCPA and explains how you can exercise those rights.
You have the right to request that we disclose which of your personal information we have collected or used over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions. After we receive and confirm your verifiable consumer request, we will delete, and/or we will 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 providers to:
To exercise the rights described above, please submit a verifiable consumer request to us by either:
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 only make a verifiable consumer request for disclosure of personal information collected twice within a 12-month period. The verifiable consumer request must:
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. 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 aim 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. 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 useable 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. Unless permitted by the CCPA we will not:
We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post a notice on our website.
If you have any questions or comments about this Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Updated: December 2019