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Privacy Statement - California

Effective: January 1, 2020

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Crain Communications Inc and its publications (collectively, “we,” “us,” or “our”) and applies solely to subscribers, website users, event attendees 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 other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

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

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

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

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 and indirectly from our customers or their employers. For example, from information that our clients provide to us related to the services for which they engage us.
  • Directly and indirectly from activity on our websites. For example, from website usage details collected automatically.
  • From third parties that interact with us in connection with the services we perform.
  • Directly from third parties.

Use of Personal Information

We may use or disclose the personal information we collect in the manner provided in our Privacy Policy, including but not limited to the following:

  • To provide you with information, products or services that you request from us. For example, we may use personal information to provide you with customer service, to process or fulfill orders and transactions, to verify customer information, to process payments, or to provide advertising or marketing services.
  • To improve our websites and present their contents to you. For example, debugging to identify and repair errors that impair existing intended functionality.
  • For testing, research, analysis and product development.
  • 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.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct [certain business transactions] 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 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:

  • 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 F: Internet or other similar network activity.
  • Category I: Professional or employment-related 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 verify your request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources of the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, 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 verify your 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:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Privacy Rights

To exercise your privacy rights described above, please submit a request to us by either filling out our Privacy Request Form (link below) or calling us at 1-877-824-9374.

You can submit a request to us to exercise the following privacy rights using the link below, which will take you to a form: Right to Know, Right to Delete, Shine the Light, and/or to submit a “Do Not Sell” request for any “sale” not related to interest-based advertising.

SUBMIT PRIVACY REQUEST

For your protection, we will take steps to verify your identity before granting access to your personal data or other information. For example, we may verify your Privacy Request by matching information you provide with our records, or you may be asked to log in to your online account (if applicable). We may request additional information to verify your identity depending on the nature of the Privacy Request and the sensitivity of the information sought. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may submit a Privacy Request to us. You may only submit a Privacy Request twice within a 12-month period.

We cannot respond to your Privacy Request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Submitting a Privacy Request does not require you to create an account with us. We will only use personal information provided in a Privacy 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. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable Privacy Request. 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 goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer webinars, white papers, events and other programs free of charge in exchange for your consent to share certain personal information, such as your name and contact information, with selected business partners. You may opt in by registering for one of these programs, but if you would like to register without providing your personal information, please fill out the Privacy Request form and you will be advised of the price difference.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-877-824-9374
Website: crain.com
Email: [email protected]

Postal Address: Crain Communications Inc
Attn: Legal Department
1155 Gratiot Avenue
Detroit, MI 48207

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