Last Updated:  May 15, 2023

B.L. Harbert International, LLC (“BLHI,” “we,” or “us”) makes the following disclosures pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”). These disclosures supplement any privacy notices we previously or contemporaneously provided to you, including any California-specific privacy notice provided to you if you are an employee of BLHI.

Right to Know

California residents have the right to be informed of the categories and specific pieces of personal information collected about them, including sensitive personal information, collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.

The below chart reflects the categories of personal information we have collected from California residents during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information.

Personal Information Category set forth in Cal. Civ. Code § 1798.140

Source(s) of Personal Information Collection

Business or Commercial Purpose(s) for Collection/Use

Third Parties, Service Providers, and Contractors Receiving Personal Information Category

Retention Period

Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license or passport number, or other similar identifiers.

Directly from you; indirectly from you as you navigate or use our website; advertising networks; internet service providers; data analytics providers.

For job applicants: Recruiters; background check providers.

Provide you with our services; maintain, improve, upgrade, or enhance our website; identify and repair errors; market to you.

For job applicants: Asses your application; satisfy legal obligations.

Social networks; technology service providers; data analytics providers; customer relationship management providers;

For job applicants and employees:

Background check providers; human resources providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or 7 years post-relationship, whichever is longer.

California Customer Records personal information (Cal. Civ. Code § 1798.80(e)), including 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.

For job applicants: Directly from you; recruiters; background check providers.

For job applicants: Process your application; satisfy legal obligations.

For job applicants and employees:

Background check providers; human resources providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or 7 years post-relationship, whichever is longer.

Characteristics of protected classifications under California or federal law.

For job applicants: Directly from you; recruiters, background check providers.    

For job applicants:

Meet our legal obligations.

For job applicants and employees:

Background check providers; human resources providers.

The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or 7 years post-relationship, whichever is longer.

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Biometric information.

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.

Indirectly from you as you navigate or use our website; advertising networks; internet service providers; data analytics providers.

Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; verify, maintain, improve, upgrade, or enhance our website or device that is owned or controlled by us; identify and repair errors; provide you with advertising or marketing services; perform analytics.

Advertising networks; technology service providers; data analytics providers.

Barring any legally required additional retention period, up to one year.

Geolocation data

Indirectly from you as you navigate or use our website; data analytics providers.

Provide you with advertising or marketing services; perform analytics.

Advertising networks; technology service providers; data analytics providers.

Barring any legally required additional retention period, up to 5 years.

Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Professional or employment-related information.

For job applicants: Directly from you; recruiters.   

For job applicants: Process your application.

For job applicants and employees:

Background check providers; human resources providers.

Barring any legally required additional retention period, up to 7 years for non-hired applicants.

Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99)

For job applicants: Directly from you; recruiters.

For job applicants: Process your application.

For job applicants and employees:

Background check providers; human resources providers.

Barring any legally required additional retention period, up to 7 years for non-hired applicants.

Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140

Sources from which Information was Collected

Purposes for Collection; Use

Third Parties, Service Providers, and Contractors Receiving Personal Information

Retention Period

Social security number, driver’s license number, state identification card, or passport number.

For job applicants: Recruiters; background check providers.

For job applicants: Process your application; satisfy legal obligations.

For job applicants and employees:

Background check providers; human resources providers.

Barring any legally required additional retention period, up to 3 years for non-hired applicants.

Account access credentials (user names, account numbers, or card numbers combined with required access code, security code or password to access an account).

For job applicants:

Directly from you.

For job applicants:

Protect against malicious, deceptive, fraudulent, or illegal activity.

For job applicants and employees:

Human resources providers.

Barring any legally required additional retention period, up to 3 years for non-hired applicants.

Precise geolocation (location within a geographical area of a circle with a radius of 1850 feet or less).

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Racial or ethnic origin

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Religious or philosophical beliefs

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Union membership

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Genetic Data

We do not collect.

We do not collect.

Not applicable.

Not applicable.

Mail, email, or text messages where the content is not directed to us.

We do not collect.

Not applicable.

Not applicable.

Not applicable.

Unique identifying biometric information

We do not collect.

We do not collect.

Not applicable.

Not applicable.

Personal information collected and analyzed concerning health.

We do not collect.

We do not collect.

Not applicable.

Not applicable.

Personal information collected and analyzed concerning sex life, or sexual orientation.

We do not collect.

We do not collect.

Not applicable.

Not applicable.

 

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also do not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

Right to Opt Out of Sharing for Cross-Context Behavioral Advertising

In the past twelve months, we have used data about your activities on our online properties to serve you ads on online properties owned or controlled by third parties. In the past twelve months, we have provided the following categories of information to advertising networks, data analytics providers, and social media networks for this purpose:

You can opt out of this sharing of personal information for cross-context behavioral advertising by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using.  To learn more about the GPC, see https://globalprivacycontrol.org/.  You may also contact us as set forth in the “Exercising Your Rights” section below.

Right to Opt Out of Sale

While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. The CCPA broadly defines “sale” in a way that may include actives such as the delivery of targeted advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior. In the past twelve months, we have provided the following categories of information to advertising networks, data analytics providers, and social media networks in ways that could be considered a “sale” under California law:

We disclosed these categories of information to these third parties for the purposes of performing analytics and marketing and to maintain, improve, upgrade, or enhance our products or services.

We have no actual knowledge of selling the personal information or the sensitive personal information or minors under 16 years of age.

California residents have the right to opt out of the “sale” of their personal or sensitive personal information.

If you would like to opt of such disclosures, you may do so by modifying your cookie settings, or, you may do so in a frictionless manner by activating Global Privacy Control (“GPC”) opt out preference signal to opt out of disclosures of your personal information through the browser you are using. To learn more about the GPC, see https://globalprivacycontrol.org/.  You may also contact us as set forth in the “Exercising Your Rights” section below.

Right to Delete Personal Information

You have the right to request the deletion of your personal information, subject to certain exceptions.

Right to Correct Inaccurate Personal Information

You have the right to request the correction of any inaccurate personal information that we maintain about you.

Right to Access

You have the right to request the categories and specific pieces of personal information we have collected about you.

Right of Non-Retaliation and Non-Discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. Company does not retaliate or discriminate against your for exercising the privacy rights conferred to you under the CCPA.

Exercising Your Rights

To exercise your rights, you may contact us at privacy@blharbert.com.  Requesters will need to provide us with personal information in order to verify their identity and residency. We will compare the information you provide with our internal records. The personal information that we use to verify identity and residency will not be used for any other purpose.

You may authorize an agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. Company may require you to verify your identity directly with us and confirm that you provided the authorized agent with permission to submit a request on your behalf.

Contact Information

If you have questions or concerns about our privacy practices, contact us at:  privacy@blharbert.com.