This PRIVACY NOTICE FOR CALIFORNIA CONSUMERS supplements the information contained in the Privacy Statement of theModern Insurance Partners family of companies (collectively, “we,” “us,” or “our”) and applies solely to California consumers (“consumers” or “you”), effective January 1, 2020. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other applicable California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice. For purposes of this notice, a “third party” is an entity that is not a wholly-owned or majority-owned and controlled subsidiary of theModern Insurance Partners family of companies.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). We collect the following categories of personal information as indicated below:

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:
  
  • 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
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
    
    

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients, prospects or employees. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients, prospects or their employees. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (www.sbspayroll.com) or other portals. For example, from submissions through our website or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we provide. For example, from government agencies when we verify data associated with payroll processing and withholding tax payments.
  
  

We may also collect personal information about you from other categories of sources such as: our affiliates; our other clients; public and publicly available sources; our third-party referral partners, vendors, data suppliers and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; social networks; news outlets and related media; and organizations with which you are employed or affiliated.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To operate, manage and maintain our business.
• To accomplish our business purposes and objectives
• To communicate with you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and service offering development.
• For vendor management purposes.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us 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.

Sharing Personal Information

WE DO NOT, AND WILL NOT, SELL YOUR PERSONAL INFORMATION. 
We may share your personal information within theModern Insurance Partners family of companies to provide services to you or in an effort to assess your needs and how we can help fulfill those needs.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we require the recipient to keep that personal information confidential and secure, to not disclose that personal information to others, and to not use it for any purpose except performing the services related to the business purpose.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category B: California Customer Records personal information categories

Category C: Protected classification characteristics under California or federal law

Category D: Commercial information

Category E: Biometric information

Category F: Internet or other electronic network activity information

Category G: Geolocation data

Category I: Professional or employment-related information

Category K: Inferences drawn from other personal information

We disclose your personal information for a business purpose to our affiliates and/or to one or more of the following categories of third parties:

• Third party service providers
• Administrators authorized by your organization
• Licensors or third-party applications (if you access a third-party application on our services through a license agreement with a licensor)
• Other parties where required by law or to protect our rights
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
  
  

In the preceding twelve (12) months, we have not sold any personal information to third parties within the scope of the application of the CCPA.

Your Rights and Choices

The CCPA provides California consumers with specific rights regarding their 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, 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 or sharing that personal information
• The affiliates we shared your personal information with
• 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 your personal information to a third party for a business purpose, separate lists identifying the personal information categories that each category of recipient obtained
  
  

Deletion Request Rights

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, 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, provide a product 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.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• 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 that information that are compatible with the context in which you provided it.
  
  

Exercising Access, Data Portability, and Deletion Rights

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

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 that you are an authorized representative of a person about whom we collected personal information
• 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. 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 (up to 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 verifiable consumer request’s receipt. 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 it is excessive, repetitive, 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.

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 products or services
• Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level or quality of products or services
• Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services
  
  

How to Make a Request

You may make a request for the disclosures or deletion described above by contacting us using one of the methods described below.

You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or the California Constitution.

Changes to Our Privacy Notice

At a minimum, this notice will be reviewed and updated on an annual basis. We reserve the right to amend this notice at our discretion and at any time. Any changes will be posted on this page with an updated revision date.