CALIFORNIA-SPECIFIC PRIVACY RIGHTS
The California Consumer Privacy Act (CCPA) went into effect on January 1, 2020. The Act allows California residents and other covered persons (the "consumer") five new rights with respect to their personal information regardless of whether there is a customer relationship or any other relationship with the covered business. Broadly, the CCPA enacts three main criteria to protect consumer data: transparency, control, and accountability. Within those criteria, the CCPA grants consumers the following rights (discussed further below): the right to access, the right to disclose, the right to delete, the right to opt-out, and the right to nondiscrimination.
CONSUMER RIGHTS UNDER THE CCPA (for California residents and other covered persons)
The Right to Access. Pursuant to the CCPA, you have the right to access personal information that has been collected, stored, or sold by us within the preceding twelve (12) month period. If you request this information, we must release it to you, but you may only make personal information requests twice in a 12-month period. If you make such a request, we will need to collect information from you to verify your identity, and will respond within forty-five (45) days of receiving a personal information request.
The Right to Disclose. We must disclose the personal information we collect or sell, and how we uses the information in response to consumer requests. This includes disclosing: the types of personal information collected, the source of the information, if the information was disclosed or sold to a third-party, the business purpose of sharing the information, the categories of personal information disclosed or sold to a third party, and the categories of third parties the information was sold or disclosed to.
If we intend to sell personal information, we must provide notice to any customer over the age of sixteen (16) and provide them with an opportunity to opt-out. If you would like to prevent disclosure of your personal information for use in direct marketing by a third party, do not opt-in to participate in these activities. If you are a California resident, and you have opted in to one of these activities, but you later decide that you would like to prevent our disclosure of your personal information to third parties for their direct marketing purposes, please contact us at firstname.lastname@example.org.
The Right to Delete. Generally, if we are contacted by a consumer requesting their personal information be deleted, we must comply. Some exceptions apply to this right.
The Right to Opt-Out. You may choose to opt-out of having your personal information sold or shared, please see below for further details. You may opt out by emailing email@example.com or filling out the form at this link: http://silvercrestadvertising.com/ccpa/.
There is a special rule for minor as noted above and below.
Right to Nondiscrimination. Under the CCPA, we may not take retaliatory or discriminatory actions against any consumer who chooses to exercise any of these rights. Thus, we cannot deny you our Service. The law prohibits any practices that are usurious, coercive, or unjust.
However, the CCPA does not prohibit entities from offering incentives, even financial, customers who chose to "opt-in" to sharing their personal information.
CATEGORIES OF INFORMATION WE COLLECT
Overview. We may collect several categories of information from and about you, including information:
- Which you may be personally identified, such as name, mailing address, e-mail address, and telephone number ("personal information"). Personal information may be collected through your own Website inputs or through third parties.
- That is about you holistically, but does not identify you personally, such as date of birth, place of birth, business phone number, business mailing address or email address, race, religion, gender, ethnicity, age or non-specific age, or geographic indicators. Such holistic information may be collected through your inputs into the Website, or through third parties; and/or.
- About your internet connection, the equipment you use to access our Website, and the pages of our Website you visit, and other usage details. Such information may be collected through cookies or web beacons (defined herein), and other similar types of automated data collection technology.
The information we gather generally falls into one of two categories: (1) information that you voluntarily supply when you register with our Service (for example, your name and address), or when you participate in the features we offer through the Service (such as comments posted on a blog, or other social networking features on the Service), and (2) information gathered on usage patterns and preferences as visitors navigate through our Service.
Registration Information. To make use of certain features available through this Service, such as to receive email newsletters, or to participate in some social networking features, you may need to register and to provide certain information as part of the registration process. Information we collect through our Website may include information that you provide when completing forms and user account or registration information on our Website, including information gathered when subscribing to our Service, requesting material, or requesting any additional services or communications, and responding to our research surveys (if any).
The information that you supply will help us to offer you more personalized features, to tailor our Service to your interests and make them more useful to you. Supplying such information is entirely voluntary. But if you don't supply the information we request, we may be unable to provide you with services we make available to other users of our Service. For instance, we can't send you email alerting you to a new service we're offering, or breaking news that may interest you, if you don't tell us what you're interested in and give us your email address.
Modifying your Personal Information. If you have a registered account you can review and edit your personal information by logging on to their account profile page. If you are unable to edit your information, you may send us an email at firstname.lastname@example.org to receive further instruction on how to correct, delete, or add any personal information you have provided to us. However, we cannot delete your personal information unless we delete your user account, and this action cannot be reversed. We can only accommodate requests to change or modify personal information to the extent allowed by applicable federal, state, and local laws.
Contests and Other Promotions. From time to time, we may offer contests, sweepstakes or other promotions via our Service. If you enter one of these contests, sweepstakes or promotions, you'll have to provide information about yourself (such as your name, address, telephone number and email address) so that we can administer and operate the contest, sweepstakes, or promotion (including contacting you if you win, fulfilling a prize, and publishing a winners' list). If you don't want us to collect the information requested in the registration form or to provide it to our co-sponsor(s) as described below, please do not enter the contest, sweepstakes or promotion.
Email Newsletters. We may also offer you the opportunity to subscribe to email newsletters that we make available through the Service. If you have opted to receive a particular newsletter, you may always unsubscribe later if you decide not to receive further mailings of the newsletter from us. See "Opting In/Opting Out" below.
Automatic Data Collection Technology. To help our site more responsive to the needs and interests of our visitors, we use several types of data collection technologies to provide a tailored browsing experience, the technologies we may use include:
- Required Cookies. Required cookies are necessary to permit the basic features of the website to function. We use some cookies that are required for the delivery of Services on our website. Cookies are a necessary component to allow us to maintain and improve user safety and security while browsing and using our website. Required Cookies allows us to authenticate registered user accounts, enable users to log into various parts of our website with a single login attempt, and determine our website's traffic and demographics. Required cookies are not used for marketing purposes.
- Flash Cookies. Flash cookies collect and store information about your preferences and navigation to and from and on our Website. Flash cookies are not managed by the same browser settings as cookies are.
- Web Beacons. Our website and emails may contain small electronic (web beacons) that allow us to receive real time statistics on user interactions such as the number of users visiting our Website, emails opened by users, and any other statistical user information.
- Clickstream Data. Clickstream data is a detailed log of how you navigate through our Website during a specific task. Generally, the log contains the pages visited, the time spent on each page, how you arrived on the page, and where you went next. In the aggregate, clickstream data is a great resource to provide real time feedback on how we can improve our website and what features you enjoy and which may cause confusion.
Browser Level Information and IP Addresses. Our web servers automatically collect limited information about your computer configuration or your mobile device when you use our Service, including the type of browser software you use, the operating system you're running, the resolution of your computer monitor or mobile device, the Website that referred you, the type of device you're using, and your IP address. (Your IP address is a numerical address that is used by computers and mobile devices connected to the Internet to identify your computer or mobile device so that data (such as the web pages you want to view) can be transmitted to you. We also use IP address information for systems administration and troubleshooting purposes. Your IP address alone does not tell us who you are. We use this information to deliver our web pages to you upon request, to tailor our Service (including ads distributed through our Service) to the interests of our users, and to measure traffic within our Service.
Social Networks. When you use one of the social network sharing tools available on our Service, the social network operating the tool may collect information about you based on such use.
Our social media platforms or online tools, including but not limited to Facebook, Twitter, Pinterest, Instagram, YouTube, (collectively, the "social media channels") are social media locations for users to connect to and learn about us through information, pictures, and videos. Our goal is to provide quality and up-to-date material about our company which we believe is useful and interesting and to our users.
We grant users a non-exclusive, non-transferable, revocable, limited access to the social media channels for your personal use and non-commercial purposes. Unless prior written consent is given by an authorized a Silvercrest officer, director, employee or agent, you may not use, copy, reproduce, modify, publicly perform or display, create derivative works of, sell, auction, lease, transfer, distribute, rent, or disclose all or any part/content of the social media channels (including, without limitation, any screenshots, videos, documentation or manuals relating to the social media channels).
We reserve all rights relating to our social media channels, including but not limited to: (i) adding, removing, or modifying any content, (ii) blocking disruptive and inappropriate users within our sole discretion; and (iii) discontinuing any of its social media channels at any time.
Information You Post. The Website may contain or include links to social media channels that contain message boards, chat rooms, personal web pages or profiles, forums, blogs, bulletin boards, discussion or comments areas, and other interactive features where you may post, submit, publish, display or transmit to other users or other persons (hereinafter, "post") content or materials on or through the Website and/or social media channels ("User Contributions").
All User Contributions must comply with the Content Standards stated herein. Please be mindful that any User Contributions on the site will be considered non-confidential and non-proprietary. By providing any contributions on the Website or related social media channels, you grant the Silvercrest Companies, and our Service Providers, and each of their and our respective licensees, successors and assigns the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties any such material for any purpose. We cannot control how your posting may be used by third parties.
Content Standards. These content standards apply to any and all User Contributions made on the Website or through our related social media channels. User Contributions must in their entirety comply with all applicable federal, state, local and international laws and regulations. Without limiting the foregoing, User Contributions must not:
- Contain any material which is defamatory, obscene, indecent, abusive, offensive, harassing, violent, hateful, inflammatory or otherwise objectionable.
- Promote sexually explicit or pornographic material, violence, or discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
- Involve commercial activities or sales, such as contests, sweepstakes and other sales promotions, or advertising.
- Infringe any patent, trademark, trade secret, copyright or other intellectual property or other rights of any other person.
- Promote any illegal activity, or advocate, promote or assist any unlawful act.
- Cause annoyance, inconvenience or needless anxiety or be likely to upset, embarrass, alarm or annoy any other person.
- Misrepresent your identity or affiliation with any person or organization.
Statistical Information. Much of the information we collect is in the form of aggregated statistics, such as the traffic that visits various pages within our Service, and the habits and preferences of our audience. Such aggregated information does not include any information that would identify you personally. We may use such aggregated information and disclose it to any third parties as we see fit.
Mobile Applications and Location-Based Information. Our Service may have the ability to use your geographic location to deliver content, services, and advertising tailored to your location. If you choose to enable our Service to use your location information, then that information will be stored and used to deliver content, services, and advertising tailored to your location. Also, when you use a mobile device or browser to access our Service, then your device and/or your browser may automatically collect and/or transmit your device's unique identifier, IP address, location information, device make/model, wireless provider, and related information to us. We may use this information to deliver content, services, and advertising tailored to your location.
DISCLOSURE OF INFORMATION
Advertisers. Without your permission, we will not share the personally-identifying information you provide when registering on our Service with advertisers. We may, however, take the information you provide and aggregate it with data from all the other people that use this Service and associated services. Then we will use that pool of information to inform our advertisers about our audience without identifying you personally.
Service Providers. We may retain other companies ("Service Providers") and individuals to perform functions on our behalf consistent with this privacy statement. Examples include data analysis firms, customer support specialists, email vendors, and web hosting companies. Service Providers may be provided with access to personal information needed to perform their functions but may not use such information other than on our behalf and in accordance with this privacy statement.
In addition, in some instances, you may be offered the opportunity to consent to the sharing of your information with a Service Provider such as an event or promotion co-sponsor. If you consent, we will share your information with such Service Provider and the information you provide may be used by such Service Provider for their own purposes and in accordance with their own policies. We will identify any co-sponsor(s) in the official rules for the promotion.
Sites to Which We Link. Our Service includes links to plenty of other Websites, and provides access to products and services offered by third parties, whose privacy policies we don't control. When you access another site or purchase products or services or conduct other transactions through their sites, use of any information you provide is governed by the privacy statement of the operator of the site you're visiting or the provider of such products or services.
OPTING IN/OPTING OUT
In certain places on this Service (for example, when registering as a user of this Service, managing your account, or participating in activities like promotional contests), we may ask you to consent to the sharing of your information with third parties with which we have business relationships. If you provide such consent (for example, by checking a box or by some other means), we will make your information available to such third parties as described in the consent form so that they, we, or both may contact you directly regarding special offers, promotions, products or services that may be of interest to you.
If you register with this Service, you will have the opportunity to review or update the information you have provided us at any time. You also have the option of deleting all information except for your email address. If you would like to completely deactivate your account, please contact us. Please note, however, that if you deactivate your account, you will not receive any newsletters from us and you will not be able to participate in any of our sweepstakes or contests.
You agree that, subject to applicable law, we may use your information to contact you for customer service, to inform you of important changes or additions to our Service or the services offered over our Service and to send you administrative notices or any communications relevant to your use of our Service.
If you have subscribed to one of our email newsletters, you will always have the opportunity to unsubscribe from future mailings (for example, by clicking on an unsubscribe link in an email newsletter or by modifying your account settings on our Service).
All information gathered through our Service is stored within database(s) operated by us or by a Service Provider on our behalf. We and/or our Service Providers secure the personally identifying information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.
The safety and security of your personal information also depends on you. You must take reasonable measures to keep all passwords, whether given or chosen, confidential. You should be mindful of using public computers and internet networks to access the Website as we are not liable for any information that may be tampered with. Information viewed in public areas may be viewed by anyone.
Although we take measures to protect your personal information, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. The transmission of personal information is at your own risk. We are not responsible for the circumvention of or tampering with any privacy setting or security measure contained on the Website.
A NOTE ABOUT CHILDREN'S PRIVACY
This Service is not directed at children under the age of 13, and we won't knowingly allow anyone under age 13 to register with our Service or to provide any other personally identifying information. If you're under 13, please do not provide us with any personally identifying information about yourself (such as your name, your email address or your phone number). If we become aware that we have collected any personally identifying information from a user under the age of 13, we will remove such information from our records as soon as possible.
CHANGES TO THIS PRIVACY STATEMENT
We may change the terms of this privacy statement or introduce new terms and conditions from time to time, in which case we will post an updated version of this privacy statement on this Service and will update the "Last Updated" date above to reflect the date the changes take effect. By continuing to use this Service after we post any such changes, you accept this privacy statement, as modified.