The Personal Information We Collect, From Where We Collect It, Why We Collect It, and With Whom We Share It
We collect, process and store various types of Personal Information. For purposes of this Policy, “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. It does not include de-identified or aggregate information, or public information lawfully available from governmental records.
The following chart describes the categories of Personal Information we may collect about you and have collected in the past 12 months and, for each category, where and why we collect it, and the categories of entities with which we have shared and continue to share the Personal Information. As you will see, our services are provided through independently-owned and operated franchises and we obtain information from them.
Categories of Consumers’ Personal Information Categories of Sources Purpose(s) for Collection of Consumers’ Personal Information Categories of Third Parties With Which Personal Information Was Shared for a Business Purpose Personal Identifiers – such as name, postal address, Internet Protocol address, email address, social security numbers, emergency contact information, or other similar identifiers Franchises Consumers directly Providing products and services Responding to consumer inquires Security processes Human resources functions Recruiting Service providers (vendors that provide services to us in connection with the operation of our business, and can include vendors that process payments, perform human resources functions, verify customer information, manage customer information, provide security services, cloud-based data storage, host our webpage and assist with other IT-related functions, advertising and marketing, provide analytics information, legal and accounting services, among other business functions) Franchises Insurance companies that retain us on behalf of their policyholders Employee benefits administrators and providers Characteristics of Protected Classes – such as gender, age, disability status, pregnancy status, citizenship, medical condition, physical or mental disability, veteran’s status Employees Human resources functions Service providers Professional or Employment information- such as information about past employers, work history, educational background, and references Job applicants Employees Recruiting agencies or platforms Referral sources Consumers who submit franchise applications Human resources functions Recruiting Evaluation of franchise application Service providers Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Franchises Consumers’ interacting with our website Providing products and services Internal marketing Franchises Insurance companies that retain us on behalf of their policyholders Service providers Internet or other electronic network activity information, including browsing and search history Consumers interacting with our website Employees Security processes Providing products and services Internal marketing
Education information Consumers who submit franchise applications Job applicants Employees Recruiting agencies or platforms Referral sources Evaluation of franchise application Human resources functions Recruiting Service providers Audio information Consumers who call our customer service line Quality assurance and training
We Do Not Sell Your Personal Information
In the last 12 months we have not sold any Personal Information. We do not and will not sell Personal Information.
Additional Information Regarding Our Collection, Use and Sharing of Personal Information
With respect to each of the categories of Personal Information we collect as noted in the chart above, we may use your Personal Information to market products or services that we think may be of interest to you, including our own products and services as well as those of our affiliates.
Additionally, we may collect and share with third parties Personal Information we collect in order to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites and mobile apps, or the public. We may also share Personal Information with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.
We may send text files (e.g., “cookies” or other cached files) or images to your web browser. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
Do Not Track
“Do Not Track” is a privacy preference that users can set in certain web browsers. We do not comply with automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.
Personal Information of Minors
Our products and services are not directed to minors under the age of 13 and we do not knowingly collect or sell the Personal Information of minors under 16.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
California Data Privacy Rights
If you are a California resident, you may have certain rights with respect to personal information as set forth under California law.
Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own marketing purposes.
CCPA Rights of Individuals
This section addresses rights provided to California residents under the California Consumer Privacy Act of 2018 (“CCPA”) regarding the Personal Information we collect. Those rights include the right to know about the Personal Information we collect, the right to request that we delete it and the right to request that we refrain from selling any Personal Information (the “CCPA Rights”). The CCPA Rights are described in greater detail below.
We note that the CCPA right to know and right to delete are subject to certain limitations, such as that they do not apply to personal information about employees, applicants, and independent contractors or information processed exclusively in the business-to-business context (e.g., information about an individual acting in his or her capacity as a representative of an entity).
In addition, in certain circumstances, we provide services on behalf of other businesses, including insurance companies. In those engagements, we do not disclose, use or retain any of the Personal Information we collect when collecting or processing Personal information on behalf of our clients for any purpose other than the specific purpose of performing the services specified in our contracts with our clients. This means that, in accordance with California law, we may not provide a substantive response to CCPA Rights requests when they concern this Personal Information we collected while providing these services. If you submit a CCPA rights request to us and we determine that we have collected your Personal Information because another business retained us to perform Services, we may direct you to the other business.
Your Right To Request Disclosure of Information We Collect and Share About You
You can request the following information from us, with respect to the Personal Information that we have collected about you in the 12 months prior to our receipt of your request:
The categories of Personal Information we have collected about you. The categories of sources from which we collected your Personal Information The business or commercial purposes for which we collected the Personal Information The categories of third parties with which we shared the information The specific pieces of Personal Information we collected
You can also submit a request to us for the categories of Personal Information that we have disclosed for a business purpose.
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon your request, we will delete the Personal Information we have collected about you that is covered by the CCPA, except for situations where specific information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Exercising Your Rights and How We Will Respond
To exercise any of the rights above, or to ask a question, contact us at (904) 737-2779, submit this form [webform], click here https://pauldavis.com/contact-us/, or use the contact details set out at the end of this Policy.
For access and deletion requests, we will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
Verification of Identity – Access or Deletion Requests
We will ask you for two pieces of Personal Information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us or not and the nature of the information your require, which we will endeavor to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Requests for Household Information
There may be some types of Personal Information that can be associated with a household (a group of people living together in a single dwelling). Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained above.
If we are unable to verify the identity of each household member with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
Our Commitment to Honoring Your Rights
Changes to This Policy
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at (904) 737-2779.