Privacy Notice for California Residents

Last Revised: 01.31.2023

This Privacy Notice for California Residents supplements the information contained in LCPtracker’s general Privacy Policy and applies solely to all website visitors, users, clients, employees and other consumers who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect 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.

Category Examples Collected

In particular, we have collected through our websites, application or other business activities the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you utilize.
• Indirectly from you. For example, by analyzing your website activity log data on our website.
• Directly from third parties. For example, see our Client Data section of our privacy policy.

Use of Personal Information

We do not sell your personal information. We may use, or disclose the personal information we collect for business purposes, including:

• Detecting security incidents and preventing fraud
• Debugging
• Performing our services
• Advertising and marketing our services
• Performing analytics and quality control
• Researching and testing to improve our services

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 Personal Information

We may disclose your personal information to third party service providers for a business purpose described above. When we disclose personal information for a business purpose, we enter into 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.

Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, LCPtracker has disclosed the following categories of personal information for a business purpose:

• Identifiers.
• California Customer Records personal information categories.
• Commercial information.
• Internet or other similar network activity.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service Providers.
• Government Entities
• Our Clients (in order to provide certified payroll, labor compliance, workforce management and other services to our clients – see Section on Client Data)

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their 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, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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.
• Upon request, the specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, a list disclosing:
  • 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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and 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 provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. 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 here.

Only you, or someone legally 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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not do any of the following based on your exercise of CCPA rights:

• Deny you services.
• Charge you different prices or rates for services.
• Provide you a different level or quality of services.

Other California Privacy Rights.

California Civil Code Section § 1798.83 permits website users that are California residents to request certain information regarding the disclosure of personal data to third parties for direct marketing purposes. To make such a request, please visit our request page here.

Changes to Our Privacy Notice.

For any changes we make to this notice, including making material changes to how we treat our users’ personal data, we will post a notice of such changes on our website home page. The date this notice was last revised is identified at the top of the page. Please be aware, you are responsible for inspecting our website to make yourself up-to-date with our privacy policy and this notice.

Contact Information.

If you have any questions or comments about this notice, the ways in which LCPtracker collects and uses your information as described in this notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please click here.