California Privacy Rights | Creative Family Connections

Your California Privacy Rights Notice

This Notice describes the rights of consumers under the California Consumer Privacy Act of 2018 (“CCPA”). Creative Family Connections LLC (the “Company”) respects your privacy. Your California Privacy Rights Notice (“California Privacy Notice”) applies solely to individual visitors, users, registrants, and others who are residents of the State of California (“consumers” or “you”).

Capitalized terms included in this California Privacy Notice that are not defined herein shall have the same definitions as set forth in the Company’s Privacy Policy, which can be found here.

Information Company Collects:

The Company collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, including the following:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; and
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, the Company may have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category	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. Some Personal Information included in this category may overlap with other categories.	YES
C. Protected classification characteristics 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.	NO
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, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	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)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

The Company obtains the above categories of Personal Information from the following categories of sources:

Directly from you if you provide your Personal Information to Company. For example, from online forms you complete or products or services you purchase from the Company.
Directly and indirectly from activity on Company’s Website or engagement with content.
Directly from Company’s prospects, customers, or their agents.
Indirectly from Company’s prospects, customers, or their agents. For example, through information Company collects from Company’s customers in the course of providing services to them or from observing their actions on our Website.

Information Company Uses:

The Company may use or disclose the Personal Information Company collects for one or more of the following purposes:

To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment. We may also save your information to facilitate new product orders.
To provide, support, personalize, and develop Company’s Website, the Content, and other Company IP.
To create, maintain, customize, and secure your account with Company.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve Company’s responses.
To personalize your experience using the Website, and to deliver Content and other product and service offerings relevant to your interests, including targeted offers and ads through Company’s Website, third-party websites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of Company’s Website, the Content, Company’s IP, other Company technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve Company’s Website and the Content.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company is among the assets transferred.

The Company will not collect additional categories of Personal Information or use the Personal Information that the Company has collected for materially different, unrelated, or incompatible purposes without providing you notice.

Information Company Shares:

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We do not sell Personal Information. In the preceding twelve (12) months, Company has not sold Personal Information. For this reason, we are not required to provide the “Do Not Sell My Personal Rights” Notice.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
B: California Customer Records personal information categories.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
C: Protected classification characteristics under California or federal law.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
D: Commercial information.	None.	None.
E: Biometric information.	None.	None.
F: Internet or other similar network activity.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
G: Geolocation data.	None.	None.
H: Sensory data.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
I: Professional or employment-related information.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.
J: Non-public education information.	None.	None.
K: Inferences drawn from other personal information.	Persons with which Company has a business relationship, including, but not limited to, clients, service providers, and independent contractors.	None.

Your Rights and Choices:

The CCPA provides consumers with specific rights regarding their Personal Information. This Section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability Rights:

You have the right to request that the Company disclose certain information to you about Company’s collection and use of your Personal Information over the past 12 months (the “Right to Know”). Once the Company receives and confirm your verifiable consumer request, the Company will disclose to you:

The categories of Personal Information Company collected about you.
The categories of sources for the Personal Information Company collected about you.
Company’s business or commercial purpose for collecting or selling (if any) that Personal Information.
The categories of third parties with whom Company shared that Personal Information.
The specific pieces of Personal Information Company collected about you (also known as your “Data Portability Rights”).
If Company sold or disclosed your Personal Information for a business purpose, two separate lists that:
- for sales, identify the Personal Information categories that each category of recipient purchased; and
- for disclosures for a business purpose, identify the Personal Information categories that each category of recipient obtained.

Right to Delete:

You have the right to request that Company delete any of your Personal Information that Company collected from you and retained, subject to certain exceptions (the “Right to Delete”). Once Company receives and confirms your verifiable consumer request, Company will delete (and direct Company’s service providers to delete) your Personal Information from Company’s records, unless an exception applies.

Company may deny your deletion request if retaining the information is necessary for Company or Company’s service provider(s) to:

Complete the transaction for which Company collected the Personal Information or otherwise perform Company’s contract with you; or
Provide a good or service that you requested; or
Take actions reasonably anticipated within the context of Company’s ongoing business relationship with you; or
Fulfill the terms of a written warranty or product recall conducted in accordance with federal law; or
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; or
Debug Company IP to identify and repair errors that impair Company’s Company IP functionalities; or
Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; or
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); or
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; or
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
Comply with a legal obligation; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Right to Know, Data Portability Rights, and Right to Delete:

To exercise your Right to Know, Data Portability Rights, and Right to Delete as described above, please submit a verifiable consumer request to Company at:

Via Email: info@creativefamilyconnections.com

Via Mail: Creative Family Connections, 2 Wisconsin Circle Suite 700, Chevy Chase, MD 20815

Only you, or someone legally authorized 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 access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows Company to reasonably verify you are the person about whom Company collected Personal Information or an authorized representative; and
Describe your request with sufficient detail that allows Company to properly understand, evaluate, and respond to it.

Company cannot respond to your request or provide you with Personal Information if Company 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 Company. Company will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format:

The Company will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt of such request. If the Company requires more time, the Company will inform the requestor of the reason and extension period in writing, which may be extended for up to an additional forty-five (45) days (90 days in total from the date of receipt of the verified consumer request).

If you have an account with us, the Company will deliver our written response to that account. If you do not have an account with us, the Company will deliver a written response via email, if your request is either made via email or an email address is provided in a verified consumer request that is mailed; provided however, the Company will provide a written response via regular postal mail to the address you provided in the consumer verified request if a response by mail is expressly requested in the consumer verified request.

Any disclosures the Company provides will only cover the 12-month period preceding the verifiable consumer request’s date of receipt. The response the Company provides will also explain the reasons the Company cannot comply with a request if that is the case. For data portability requests, Company 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.

The Company does not charge a fee to process or respond to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded and unreasonable. If the Company determines that a fee is warranted for your request, the Company will inform you the reasons under which the Company has warranted such fee and provide you with an estimated cost of such fee prior to completing your request.

Non-Discrimination:

The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not:

Deny you goods or services; or
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; or
Provide you a different level or quality of goods or services; or
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, the Company may offer you certain financial incentives as part of a financial incentive program (“Program”) permitted under the CCPA that could alter the prices, rates, or quality levels of the goods or services you receive. Any CCPA-permitted Program that the Company offers will reasonably relate to your Personal Information’s value and contain written terms describing the material details of such Program. Your prior “opt in” consent, which you may revoke at any time, is required to participate in any such Program.

Other California Privacy Rights:

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits the Company’s Website users, which are California residents, to request certain information pertaining to the Company’s disclosure of Personal Information to third parties for their direct marketing purposes. Please contact Company to make such a request.

Privacy Notice Changes:

The Company reserves the right, in its sole discretion, to update, change, modify, add, or remove portions of this California Privacy Notice from time to time and without notice. No amendment, modification, extension, limitation, waiver, or termination of this California Privacy Notice by you shall be valid except with the written consent of the Company. The Company encourages you to periodically review this page for the latest information regarding the Company’s California Privacy Notice. Your continued use of the Website and other Company IP is subject to the most current effective version of Company’s California Privacy Notice. If you object to this California Privacy Notice after it becomes effective for you, you may no longer use or access the Company IP, including the Website.