CCPA Supplementary Privacy Policy

Privacy notice for California residents - Published 1st January 2020

This Privacy Notice for California Residents supplements the information contained in PCS Publishing’s Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer, household, or device (“personal information”). Personal information does not include:

·Publicly available information from government records.

·Deidentified or aggregated consumer information.

Our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category: Identifiers.

Examples:

  • All Website Users: Internet Protocol (IP) address

  • Website users who interact with features of our website and services*: Last name, first name, email address, postal address, phone numbers

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

Examples: ​

  • Website users who interact with features of our website and services*: Last name, first name, email address, postal address, phone numbers

  • Job Applicants Only: Education, employment, employment history.

  • Some personal information included in this category may overlap with other categories.

Category: Protected classification characteristics under California or federal law.

Example: ​

  • Job Applicants Only: Age (40 years or older), race (voluntary), national origin (voluntary), sex (voluntary – including gender, gender identity, gender expression).

Category​​: Commercial information.

Example: ​              

  • Customers only: records of Services purchased, obtained, or considered; other purchasing or consuming histories or tendencies.

Category: Internet or other similar network activity.

Example: ​

  • Browsing history, search history, information on your interaction with our Website and Services, or advertisement.

Category: Sensory data.

Example:

  • Customers only: Audio or visual information i.e. recording of product feedback.

Category: Professional or employment-related information.

Example:

  • Job candidates only: current or past job history or performance evaluations (i.e. references).

Category: Geolocation data​

Example:​

  • The physical location associated with an IP address or account data​

Our Website obtains the categories of personal information listed above from the following categories of sources:

 

  • * Directly from you. For example, when you create an account, participate in any interactive features of our Website and Services (e.g. posting, sharing, sending and receiving comments through the Website and Services), fill out a form, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us.

  • Indirectly from you. For example, from observing your actions on our Website or when you access and use our Services.

  • From third party sources, including mailing list providers, providers of identity verification services and social media networks

 

Use of Personal Information

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

To fulfil or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products and services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new products and service orders.

  • To provide, support, personalise, and develop our Website, products, and services.

  • To create, maintain, customise, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and 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 personalise your Website experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email (with your consent, where required by law).

  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Website, products and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • To review your application for a job position at our company.

  • 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, reorganisation, 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 about our Website users 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 may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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

  • Identifiers.

  • California Customer Records personal information categories.

  • Protected classification characteristics under California or federal law.

  • Commercial information.

  • Internet or other similar network activity.

  • Sensory data.

  • Professional or employment-related information.

  • Geolocation data

We disclose your personal information for a business purpose to such service providers providing such services as set forth and included in the Privacy policy.

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

Your Rights and Choices

The CCPA provides consumers (California residents) 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 (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 your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.

  • Deletion request 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 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 provider(s) 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, fulfil the terms of a written warranty or product recall conducted in accordance with federal law, 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 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.).

      • 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 legal obligation.

      • Make other internal and lawful uses of that information that are compatible with the context in which you provide 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:

      • Emailing us at info@pcs-publishing.com

      • Calling us on: 0800 776 5848

      • Writing to us at PCS Publishing, Castle Street, Wolverhampton, WV1 3AD, United Kingdom

    • Only you, or someone legally authorised 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. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

    • We will only use personal information provided in a verifiable consumer request (i.e. via a validated email account) to verify the requestor’s identity or authority to make the request.

  • Response Timing and Format

    • We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

    • If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 Services.

      • Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties.

      • Provide you a different level or quality of Services.

      • Suggest that you may receive a different price or rate for Services or a different level or quality of Services.

  • Other California Privacy Rights

    • California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are 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 send an email to info@pcs-publishing.com, or call us on: 0800 776 5848, or write to us at: PCS Publishing, Castle Street, Wolverhampton, WV1 3AD, United Kingdom.

Changes to this Policy

Any changes to our Privacy Policy will be placed here and will supersede this version of our Policy. We will take reasonable steps to draw your attention to any changes in our Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.

Contacting Us

If you have any questions about our Privacy Policy, or if you want to know what information we have collected about you, please email us at info@pcs-publishing.com, or call us on: 0800 776 5848, or write to us at: PCS Publishing, Castle Street, Wolverhampton, WV1 3AD, United Kingdom.