PRIVACY POLICY
Last updated: [10/20/2021]
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Scope of Privacy Policy
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Information FCA Collects and How it is Collected
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Sources of Information FCA Collects
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How Your Information is Used
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Protection of Personal Information
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California and Nevada Residents
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Definitions
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Changes
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Contact information
1. Scope of Privacy Policy
First Choice Auditors ("FCA" or "We") respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy (“Privacy Policy”) describes the types of information we may collect from you when you use our website (“Website”). This Privacy Policy (“Privacy Policy”) is designed to provide transparency into our privacy practices, such as what information we collect from you, how we use this information, to whom it is shared, how it is stored, and, and more.
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This policy applies to information we collect:
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On this Website.
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In email or other electronic messages between you and this Website.
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Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
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If you use a portal maintained by FCA, including those not accessed through this Website.
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Between you and FCA through email or telephonic communications, in-person or remote face-to-face interactions, or mail services.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
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2. Information FCA Collects and How it is Collected
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We collect several types of information from and about users of our Website, including information:
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By which you may be personally identified, such as name, postal address, e-mail address, telephone number, security number, credit profile, payment information, or any other identifier by which you may be contacted online or offline ("personal information");
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That is about you but individually does not identify you, such as the name of the company you represent or work for; and/or
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About your internet connection, the equipment you use to access our Website, and usage details[KE1] [LA2] [KE3] [LA4] .
We collect this information:
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Directly from you when you provide it to us.
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Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking technologies.
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From third parties, for example, our business partners.
3. Sources of Information FCA Collects
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Information You Provide to Us
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The information we collect on or through our Website may include:
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Information that you provide by filling in forms on our Website. This includes information provided at the time of signing up for our newsletter.
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Records and copies of your correspondence (including email addresses).
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Your responses to surveys that we might ask you to complete for research purposes.
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Records of telephone communications.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
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Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.[H5] [LA6] [KE7] [LA8]
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Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
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Estimate our audience size and usage patterns.
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Store information about your preferences, allowing us to customize our Website according to your individual interests.
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Speed up your searches.
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Recognize you when you return to our Website.
Cookies
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The technologies we use for this automatic data collection may include:
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Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
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Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Categories of Cookies we collect:
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Category Name. Description of purpose.
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Category Name. Description of purpose.
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Category Name. Description of purpose.
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Category Name. Description of purpose.[H9] [LA10] [KE11] [LA12]
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.
4. How Your Information is Used
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We use information that we collect about you or that you provide to us, including any personal information:
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To present our Website and its contents to you.
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To provide you with information, products, or services that you request from us.
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To fulfill any other purpose for which you provide it.
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To provide you with notices about your account, including expiration and renewal notices.
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To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
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To notify you about changes to our Website or any products or services we offer or provide though it.
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In any other way we may describe when you provide the information.
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For any other purpose with your consent.
We may also use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, you may unsubscribe or ask to be placed on our do not call list using the contact information listed in Section IX of this Privacy Policy.
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Information sharing
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Reasons we can share your info:
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For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.
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For our marketing purposes—to offer our products and services to you. For joint marketing with other financial companies.
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For our affiliates’ everyday business purposes—information about your transactions and experiences.
Purpose of information sharing
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We share your information with necessary parties to help facilitate the products and services that you have contracted for. We share your information with vendors that assist us in offering various opportunities to you. We occasionally share information with other financial and non-financial entities. We also share your information with affiliated parties to help facilitate your goals.
Permitted uses for information sharing
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
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To our subsidiaries and affiliates.
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To contractors, service providers, and other third parties we use to support our business [and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them].
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To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FCA's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FCA about our Website users is among the assets transferred.
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To fulfill the purpose for which you provide it. For example, if you give us an email address to use be added to the newsletter mailing list.
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For any other purpose disclosed by us when you provide the information.
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With your consent.
We may also disclose your personal information:
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To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
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To enforce or apply our Terms of Service[H13] and other agreements, including for billing and collection purposes.
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If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FCA, our customers, or others.
Limiting information sharing:
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Although federal law does not require us to, we give you the right to limit any sharing that is not directly needed to facilitate our contracted services and or delivery of contracted products. Information can be limited as long as it is not information that is shared with necessary parties to help facilitate the products and services you have contracted for. You can opt out of receiving any marketing from us for any products other than the products or service you have contracted for. You can also opt out of any non-essential sharing with third parties. To limit our sharing of information or for ANY Questions: call us at (800) 281-0411.
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Please note if you are a new customer we can begin sharing your information thirty (30) days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
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California and Nevada residents may have additional personal information rights and choices. Please see Section VI of this Privacy Policy - California and Nevada residents[H14] .
5. Protection of Personal Information
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To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards, encrypted storage of all personal information, data security and breach protocols and secured files and buildings. All employees are trained and monitored on privacy and security protocols, we monitor all offices with cameras, and protect them with monitored alarm systems, we additionally destroy all physical documents after they are no longer needed and keep electronic copies of them in a secure encrypted environment.
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The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
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Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
6. California and Nevada residents
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In response to a California law, we will automatically treat individuals with a California billing addresses as if they had requested us not to share their information with non-affiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us. Residents of the State of California may request a list of all third-parties to which we have disclosed certain information during the preceding year for those third-parties' direct marketing purposes.
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This Privacy Policy for California Residents supplements the information contained in FCA’s Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). 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 Policy.
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Information We Collect
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See Section III[H15] of the privacy policy. Personal information does not include:
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Publicly available information from government records.
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Deidentified or aggregated consumer information.
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Information excluded from the CCPA's scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA).
In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:
Category[KE16] [LA17]
Examples
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.
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.
C. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
D. 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.
E. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
F. Professional or employment-related information.
Current or past job history or performance evaluations.
G. 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.
H. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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See Section II [H18] of the Privacy Policy to learn how our Website obtains these categories of personal information.
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Use of Personal Information
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We may use or disclose the personal information we collect for one or more of the following purposes:
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To fulfill or meet the reason you provided the 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 and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
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To provide, support, personalize, and develop our Website, products, and services.
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To create, maintain, customize, and secure your account with us.
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To process your requests, purchases, transactions, and payments and prevent transactional fraud.
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To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
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To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
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To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
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For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
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To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
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As described to you when collecting your personal information or as otherwise set forth in the CCPA.
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To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
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.
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Sharing Personal Information
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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. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose.
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We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information for a business purpose.
Personal Information Category
Category of Third-Party Recipients[H19] [LA20] [KE21] [LA22]
Business Purpose Disclosures
Sales
A: Identifiers.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
B: California Customer Records personal information categories.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
C: Protected classification characteristics under California or federal law.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
D: Commercial information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
E: Biometric information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
F: Internet or other similar network activity.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
G: Geolocation data.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
H: Sensory data.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
I: Professional or employment-related information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
J: Non-public education information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
K: Inferences drawn from other personal information.
[None/[THIRD-PARTY CATEGORIES]]
[None/[THIRD-PARTY CATEGORIES]]
Right to Know and Data Portability
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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 twelve (12) months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:
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The categories of personal information we collected about you.
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The categories of sources for the personal information we collected about you.
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Our business or commercial purpose for collecting or selling that personal information.
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The categories of third parties with whom we share that personal information.
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If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
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sales, identifying the personal information categories that each category of recipient purchased; and
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disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
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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 (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
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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.
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Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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Debug products to identify and repair errors that impair existing intended functionality.
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Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
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Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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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.
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Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
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Comply with a legal obligation.
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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.
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Exercising Your Rights to Know or Delete
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To exercise your rights to know or delete described above, please submit a request by either:
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Calling us toll free at (800) 281-0411 .
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Emailing us at clientservices@FirstChoiceAuditors.com.
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Visiting ww.firstchoiceauditors.com.
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By logging into the client portal at https://portal.firstchoiceauditors.com/Portal/login.jsp and sending a secured message to our client services team.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
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You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
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Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, but may not be limited to:
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Name, social security number, and mailing address.
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Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
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You do not need to create an account with us to submit a request to know or delete.
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We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
Response Timing and Format
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We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at the information listed in Section IX of this Privacy Policy.
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We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.
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If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
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Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. 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.
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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.
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Personal Information Sales Opt-Out and Opt-In Rights
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If you are age sixteen (16) or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than sixteen (16) years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
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Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
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We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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Deny you goods or services.
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Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
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Provide you a different level or quality of goods or services.
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Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
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California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the information listed in Section IX of this Privacy Policy.
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Nevada Residents
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In response to Nevada law, we are providing you this notice. You may be placed on our internal Do Not Call List by contacting us at the address set forth above. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.
7. Definitions
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Affiliates: Companies related by common ownership or control. They can be financial and non-financial companies.
Non-Affiliates Companies not related by common ownership or control. They can be financial and non-financial companies.
Joint Marketing: A formal agreement between non-affiliated financial companies that together market financial products or services to you.
8. Changes
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We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated policy on the Website and update the policy’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
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9. Contact information
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To ask questions or comment about this privacy policy and our privacy practices, contact us at:
clientservices@firstchoiceauditors.com
or via our toll-free number:
(800) 281-0411