Privacy Notice For California Residents

Last updated: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of Jerome Alexander Consulting Corporation (“Jerome Alexander,” “we,” or “us”), which is incorporated in this privacy notice by this reference. This privacy notice applies solely residents of the State of California about whom we collect personal information (“consumers” or “you”), including, for example, visitors to our websites (the “Sites”) and our customers who make purchases on the Sites. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (as amended, and together with the California attorney general’s implementing regulations, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Information We Collect

We may collect 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 (“personal information”). In particular, we have collected the following categories of personal information from its consumers within the last 12 months for the business or commercial purposes described below:

Description What We Collect Source Business or Commercial Purposes for Collection

Identifiers.

A real name, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name.

Directly from consumers

Indirectly from consumers (e.g., through cookies or interaction with our websites)

Fulfilling purchases

Responding to communications with consumers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, address, telephone number, credit card number, debit card number,

Directly from consumers

Fulfilling purchases

Responding to communications with consumers

Protected classification characteristics under California or federal law.

Collect none of these

Commercial information.

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Directly from consumers

Indirectly from consumers (e.g., through cookies or interaction with our websites)

Fulfilling purchases

Responding to communications with consumers

Internet or other similar network activity.

Browsing history, search history, or information on a consumer’s interaction with a website, application, or advertisement.

Directly from consumers

Indirectly from consumers (e.g., through cookies or interaction with our websites)

Third-party service providers (e.g., analytics companies)

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as 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) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:

  • To process your requests, purchases, payments, and transactions and to 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 our responses.
  • To create, maintain, customize, and secure your account with us.
  • For testing, research, analysis, and product development, including to develop and improve our Sites and our products and services.
  • To provide, support, personalize, and develop our Sites and our products and services.
  • To help maintain the safety, security, and integrity of our Sites and our products, services, databases, other technology assets, and business.
  • To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Sites, third-party sites, and via email or text message (with your consent, where required by law).

We will continue to collect the categories of personal information described above for the business or commercial purposes described above. We may also use or disclose the personal information we collect for one or more of the following purposes:

  • 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 Jerome Alexander’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Jerome Alexander about the users of our Sites 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.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have not disclosed the categories of personal information for a business purpose.

Sales of Personal Information

In the preceding 12 months, we have not sold personal information.

Your Rights and Choices

The CCPA provides you as California residents with specific rights regarding your 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. 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 that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed for a business purpose or sold your personal information, two separate lists disclosing:
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Sales, identifying the personal information categories that each category of recipient purchased.

Deletion of your Information

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 providers to:

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

  • Calling us at: 888-886-6304
  • Emailing us at support@jeromealexander.com.

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. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • 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.

Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.

We 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

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer 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.

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive 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. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we 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, including denial 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 goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, levels, or quality of goods or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits 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 set forth below.

Changes to this Privacy Notice

Jerome Alexander reserves the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on our Sites and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing our Sites and this privacy notice to check for any updates or changes. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes.

Contact Us

If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us at:

Phone: 888-886-6304

Email: support@jeromealexander.com

Postal Address:

Jerome Alexander Consulting Corporation

C/O Customer Service / CCPA

15820 Euclid Avenue

Chino, California 91708

Copyright © 2020, Inc. All rights reserved.