Effective Date: January 1, 2020.
CCPA Policy only applies to consumers’ whose Personal Information is collected, used or disclosed by PPIB. Personal Information is defined below. Any other terms defined in the CCPA have the same meaning when used in this CCPA Policy.
This CCPA Policy describes PPIB’s business practices, both online and offline, regarding:
NOTE: PPIB does not sell consumers’ Personal Information. PPIB does not sell the Personal Information of minors under 16 years of age without affirmative authorization.
“Personal Information” means 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 does not include:
■ Publicly available information from government records.
■ De-identified or aggregated consumer information.
■ Information excluded from the CCPA’s scope, like:
I. Right to Know
Consumers have the right to request that PPIB disclose certain Personal Information PPIB has collected about them during the last 12 months. PPIB will not disclose any Personal Information unless it receives a Verifiable Consumer Request (Information on how to complete a Verifiable Consumer Request is found below*). Consumers have the right to request the following:
II. Right to Request Deletion
Consumers have the right to request that PPIB delete any of their Personal Information that PPIB collected from them and retained, subject to certain exceptions. Once PPIB receives a Verifiable Consumer Request - and separately confirms the Verifiable Consumer Request to delete- PPIB will delete (and direct its service
providers to delete) the Personal Information from its records, unless an exception applies. Information on how to complete a Verifiable Consumer Request to delete is found below.
PPIB may deny a deletion request if maintaining the information is necessary for PPIB to:
III. Exercising Right to Know and Right to Delete
To exercise the right to know and right to delete described above, please submit a Verifiable Consumer Request to PPIB by either:
making the request and has not provided registration information or a power of attorney, PPIB must receive written permission from the consumer for the Agent to act on the consumer’s behalf.
Consumers may only make a Verifiable Consumer Request for access or deletion twice within a 12-month period. The Verifiable Consumer Request must:
PPIB will attempt to match data provided in the Verifiable Consumer Request to data that PPIB maintains on the consumer. PPIB will require a declaration under penalty of perjury, swearing that the requestor is the consumer or Authorized Agent whose Personal Information is the subject of the request. If PPIB cannot, to a reasonably high degree of certainty, verify a requestor’s identity or authority to make the request and confirm the Personal Information relates to the consumer, the request will be denied. PPIB will also deny a request made by an Authorized Agent if the Authorized Agent does not submit proof that they have been authorized by the consumer to act on their behalf, as described above. If this happens PPIB will state so in its response.
Making a Verifiable Consumer Request does not require the requestor to create an account with PPIB. PPIB will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor’s identity or authority to make the request.
PPIB will provide a response either by mail or electronically, at the requestor’s option.
IV. Verifiable Consumer Request Response and Timing
PPIB will confirm receipt of a Verifiable Consumer Request within 10 days of receipt and, upon verification, provide a response within 45 days. PPIB may require an additional 45 days to verify and respond to some requests. If more than 45 days are required, PPIB will notify the requestor within the first 45 days, explaining the reason for the delay.
PPIB will not charge a fee to process or respond to a Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If PPIB determines that the Request warrants a fee, it will inform the requestor of that decision.
PPIB will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
VI. Categories of Personal Information PPIB has Collected in the Last 12 Months:
The categories of Personal Information PPIB has collect about consumers over the past 12 months include the following:
A. Personal Identifiers: such as a real name, signature, physical characteristics, physical description, alias, postal address, IP address, email address, telephone number, passport number, social security number, driver’s license or state identification card number.
B. Financial Identifiers: such as insurance policy number, bank account number, credit card number, debit card number, or any other financial information.
C. Medical Information: such as health insurance or medical information, unique personal identifier for health insurance, online identifier, account name, or other similar identifiers;
D. Employment and Education Information: such as education history, employment or professional history, education information, as defined in FERPA.
E. Protected classifications under California or federal law, including: age, race, color, sex, creed, gender, sexual orientation and identity, national origin, disability, citizenship status, marital status, military or veteran status.
F. Commercial information, records of products or services purchased, obtained, or considered.
G. Internet or other electronic network activity information, including, but not limited to, search history, and information regarding a consumer’s interaction with an Internet Web site, or application.
H. Audio, electronic, or similar information, including recordings of phone calls or messages left on a PPIB phone system.
VII. Categories of Sources from Which PPIB Has Collected the Categories of Personal Information Described Above:
The categories of sources from which PPIB collects Personal Information and the specific categories of Personal Information vary, depending upon the particular nature of the interaction with each consumer.
VIII. Business or Commercial Purposes For Which PPIB Has Collected the Categories of Personal Information Described Above:
● To provide products and services that are requested
● 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.
● Undertaking activities to verify or maintain the quality or safety of a service or product that is developed or provided by PPIB, and to improve, upgrade, or enhance any service or product that is developed or provided by PPIB.
● Auditing related to a current interaction with a consumer and concurrent transactions including auditing for compliance with the CCPA and other standards.
● Undertaking internal research for technological development and demonstration.
● Undertaking activities to verify or maintain the quality of services and products owned or controlled by PPIB and to improve, upgrade or enhance those services and products.
● Advancing PPIB’s lawful commercial or economic interests.
IX. Categories of Third Parties With Whom PPIB Has Shared Personal Information Described Above:
PPIB may share consumer Personal Information with a third party for a business or commercial purpose. When PPIB discloses Personal Information for a business or commercial purpose, it enters into a contract that describes the purpose and requires the third party recipient to both keep the Personal Information confidential and not use it for any purpose except performing the contract.
PPIB shares your Personal Information with the following categories of third parties:
X. Disclosures of Personal Information Described Above for a Business or Commercial Purpose:
PPIB has disclosed the following categories of Personal Information to third parties in the preceding 12 months for a business or commercial purpose:
All categories of Personal Information.
PPIB has not sold any Personal Information to third parties for a business or commercial purpose in the preceding 12 months.
NOTICE: Nothing in this CCPA Policy or the CCPA shall limit PPIB’s ability to comply with applicable laws; comply with civil, criminal, or regulatory inquiries by federal, state or local authorities; cooperate with law enforcement concerning any potential violations of law; or otherwise exercise or defend legal claims.
This CCPA Policy may be printed as a separate document by utilizing your browser’s print function.
XI. Contact for More Information:
Persons with a disability can receive alternative formats of this CCPA Policy by contacting PPIB below. If a consumer has any questions or concerns about this CCPA Policy or any consumer rights under the CCPA, PPIB can be contacted at:
2775 N Ventura Road
Oxnard, CA 93036
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