Privacy Policy
Scope of Notice
This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”). This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
When we use the term “personal information” in this CA Notice, we mean 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 CA Notice does not apply to personal information we collect when we are acting as a service provider to process information on behalf of our clients to whom we provide legal services.
For the purposes of this CA Notice, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not
- capable of being associated with or linked to a consumer.
- 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) or clinical trial data.
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other Greystone personnel.
Collection and Use of Personal Information
We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Personal Information We Collect About You and How We Use It section in our Privacy Notice.
In the last 12 months, we may have collected the following categories of personal information:
- Identifiers, such as your name, address, phone number, email address, or other similar identifiers.
- Commercial Information, such as your use of our services.
- Protected Classification Characteristics, such as age, gender, religion, and disability information.
- Internet/Network Information, such as your IP address, or browser or device information.
- Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.
- Sensory Information, such as pictures of you.
- Professional/Employment Information, such as your employing entity, business unit, manager and management reporting structure, job title, function and the nature or your duties and responsibilities.
- Other Personal Information, such as information you provide to us when you register for or attend an event organized or hosted by us, including your preferences or education information, information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you post on message boards, blogs or complete an online form, and any health screening information you provide to us.
- Inferences, including information generated from your use of the websites reflecting predictions about your interests and preferences.
Sources of Collecting Personal Information
We collect this information from a variety of sources including, but not limited to:
- Directly from you.
- From your browser or device.
- From information generated from your online browsing and usage activity.
- Service providers.
- Business partners and affiliates.
- Third parties you direct to share information with us.
Purposes for Collecting Personal Information
We may collect, use or disclose personal information about you for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry.
- To deal with enquiries and complaints made by or about you relating to our services.
- To communicate with you, including through email to provide you updates, alerts, news and mailings relating to seminars or events that we think may be of interest to you.
- To operate, maintain, and provide to you the features and functionality of our services.
- To market to you, including through email.
- To send you statements and invoices in relation to any agreement between us to provide you with any part of the services.
- To better understand the demographics of our users.
- To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, or on other devices you may use.
- To recognize you and remember your information when you return to our websites and services.
- To help maintain the safety, security, and integrity of our services, technology assets, and business.
- To protect the health and safety of our personnel and visitors to our premises.
For testing, research, analysis, and product development, including to develop and improve our services. - To assist you in sharing content from our services, or your experiences on our services, with your friends, followers or contacts on a social network.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Disclosure of Personal Information
In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the Collection and Use of Personal Information section of this CA Notice, to third parties for a business purpose. We do not sell personal information to third parties.
Recipients of Personal Information
As described in the Recipients of Personal Information section of our Privacy Notice, we share personal information within Greystone and with a variety of third parties for business purposes.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law).
| The Right to Access/Know | You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
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| The Right to Request Deletion | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| The Right to Opt Out of Personal Information Sales | You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. |
| The Right to Non-Discrimination | You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
| “Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83). |
Minors Under Age 16
We do not and will not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at contactus@greystonelawgroup.com to inform us if you, or your minor child, are under the age of 16.
California’s “Shine the Light” Law
In addition to the rights described above, California’s “Shine the Light” law (California Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to contactus@greystonelawgroup.com This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this section.
Updates to This CA Notice
We will update this CA Notice from time-to-time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to contactus@greystonelawgroup.com.