RNN Group, Inc.



CALIFORNIA CONSUMER PRIVACY ACT NOTICE FOR CALIFORNIA RESIDENTSWhy RNN is Providing This Notice to YouThis Notice only applies to California consumers and is provided in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). If you are a California Resident, then the information listed below may apply to you in addition to any other Privacy Policies of RNN. This notice is intended to augment, and not replace, RNN’s current Privacy Policy. The information below is intended to inform California consumers about how RNN may collect, may use, may disclose, or may process California consumers’ personal information regardless of the method of collection of that personal information. “Personal Information” is that certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This Notice Does NOT Apply to All Types of Information and ONLY Applies to California Consumers and ResidentsThis notice does NOT cover Personal Information that RNN collects, obtains, processes, sells or discloses subject to the CCPA exemptions. Under the CCPA, Personal Information does not include publicly available information from government records or certain de-identified or aggregated consumer information. Furthermore, the CCPA does not apply at all to some specific types of information. These types of information include: a) health or medical information covered by the Health Insurance Portability and Accountability Acc of 1996 (“HIPPA”), the California Confidentiality of Medical Information Act (“CMIA”), or certain clinical or trial data; b) personal information covered by other specific privacy laws such as the federal Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act (“FCRA”), the California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”). RNN is governed by both the GLBA and the FCRA and the majority, if not all, of the personal information that RNN collects on California consumers is done so under either the GLBA or the FCRA and is therefore exempt from CCPA requirements. Furthermore, RNN is a “Service Provider” as defined by the CCPA. California Consumer Privacy Rights and How to Exercise ThemThe CCPA provides California consumers and residents with specific rights regarding non-exempt Personal Information. Generally, those rights are the right to know what Personal Information of a California consumer and resident has been collected about that California consumer and resident, to know what Personal Information has been disclosed about that California consumer and resident, and to know what Personal Information about that California consumer and resident has been sold to another party. These rights are discussed in more detail below. Collection and use of Personal rmation Collected by RNN. RNN may collect several types of Personal Information in providing services to its clients as a Service Provider. This information could include:categories and identifiers such as real name, aliases, unique personal identifiers, postal address, email address, IP address, account names, social security number, military status, driver’s license number, employment, employment history, bank account number, brokerage or annuity information, credit card number, debit card number, or other similar identifiers; inferences from Personal Information used to create a profile about you that could reflect your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; andaudio or electronic or similar information. RNN’s Sources for Acquiring Personal Information. Publicly accessible sources;vendors;clients;directly and indirectly from the RNN website;employers; anddirectly and indirectly from consumers.RNN’s use and/or Disclosure of Personal Information. RNN may use or disclose Personal Information:in performing services on behalf of or for a client or service provider, including verifying client information, augmenting client information with up-to-date information, and fulfilling contractual requirements;providing you with information or services you request of RNN;audit and quality control;detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity and prosecuting those responsible for that activity;debugging to identify and repair errors that impair existing intended functionality;short-term, transient use where the Personal Information is not disclosed to another third party and is not used to build a profile about a consumer; andto respond to requests from law enforcement or to comply with judicial requirements.California consumer rights under the CCPA.As a California consumer and resident, you may have the right to request, twice in a 12-month period, the following information about the non-exempt Personal Information RNN has collected about you during that same 12-month period:the categories and specific pieces of non-exempt Personal Information RNN collected about you;the categories of sources from which RNN collected the non-exempt Personal Information;the business or commercial purpose for which RNN collected or sold the non-exempt Personal Information;the categories of third parties with whom RNN shared the non-exempt Personal Information; and the categories of non-exempt Personal Information about you that RNN sold or disclosed for a business purpose and the categories of third parties to whom RNN sold or disclosed that information for a business purpose. As a California consumer and resident and upon proper verification, you may have the right to request that RNN delete any non-exempt Personal Information collected or maintained by RNN on you. RNN may deny you deletion request if RNN is acting in the role of Service Provider to another business regarding the applicable Personal Information. If RNN denies your request based upon that basis, RNN will generally refer you to the relevant business. In addition, RNN may deny your deletion request if retaining the information is necessary for RNN’s client to do one of the following:complete the transaction for which the Personal Information was collected, provide a good or service requested by you, as reasonably anticipated within the contest of your relationship with the relevant business, or otherwise perform a contract between you and the business;detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;debug to identify and repair errors that impair existing intended functionality;exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided by law;comply with the California Electronic Communications Privacy Act;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 RNN’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided RNN has obtained your informed consent;enable solely internal uses that are reasonably aligned with your expectations based upon your relationship with the relevant business;comply with a legal obligation;otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information; orif another CCPA exemption applies. As a California consumer and resident, you may have the right to non-discrimination for goods and services based upon or as a result of your utilization of the rights afforded you by the CCPA. Unless permitted under the CCPA, RNN will not:deny you goods or services;charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;provide you a different level or quality of goods or services;suggest that you may receive a different price or rate for goods or services or a different level or quality of good or service. How to exercise your rights. Submitting a Request.RNN shall take steps to verify your identity prior to responding to any request under the CCPA. Should you be unwilling to provide RNN the necessary information required to verify your identity then RNN will be unable to fulfill any request under the CCPA.call RNN toll free at its designated CCPA extension: 1-866-466-5996, ext. 711; oremail the RNN compliance team with your request at compliance@.Who May Submit a Request.you on behalf of yourself;you on behalf of your minor child;an authorized individual on your behalf. Should you designate someone else to make the request on your behalf, RNN shall require:that individual to provide a valid power of attorney to request the information on your behalf; orwritten authorization from you allowing that person to make the request on your behalf. In the absence of a valid power of attorney, RNN shall require your agent to verify their identity as well before RNN responds to the request.Any information that RNN obtains in the process of verifying or responding to a request shall be used solely for that purpose. Verifying Your Identity. If you are a California consumer and resident and choose to assert your CCPA rights on non-exempt Personal Information, you must:Provide RNN enough information to reasonably identify you which may include a combination of identifiers such as: reference ID, date of birth, full name, last 4 of social, address, etc. The information necessary may differ based upon your specific request; andDescribe your request with enough detail to allow RNN to properly address and respond to your request. When and How RNN Will Respond to a Request. RNN shall employ best efforts to respond to verifiable requests made under the CCPA within 45 days. RNN reserves the right to extend that response period if it provides you notice of the extension within that initial 45-day period. The response shall ultimately cover the 12-month period preceding initial receipt of the request. RNN’s response shall also explain the reasons why it cannot comply with the request, or is not obligated to comply with the request, if applicable. RNN is only obligated to respond to a maximum of two requests per California consumer and resident per 12 months. Last updated 1/13/2020. All rights reserved. ................
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