California Consumer Privacy Act (CCPA) Notice

1. Introduction

This California Consumer Privacy Act (CCPA) Notice supplements our Privacy Policy and applies specifically to California residents. The CCPA provides California residents with specific rights regarding their personal information.

This notice describes how Earnest Benefit collects, uses, and shares personal information of California residents and explains the rights California residents have under the CCPA.

2. Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information from California residents:

2.1 Identifiers

• Name, email address, postal address, phone number
• IP address, device identifiers, online identifiers
• Account usernames and passwords

2.2 Personal Information Categories Listed in the California Customer Records Statute

• Name, signature, address, telephone number
• Learning, employment, employment history
• Monetary information (income range, monetary status)

2.3 Commercial Information

• Records of products or services purchased, obtained, or considered
• Other purchasing or consuming histories or tendencies

2.4 Internet or Other Electronic Network Activity Information

• Browsing history, search history
• Information regarding a consumer's interaction with our website or application
• Device information and usage patterns

2.5 Geolocation Data

• General location information (city, state, ZIP code)
• Precise location data (with consent)

2.6 Sensory Data

• Audio recordings of customer service calls (with notice)

2.7 Professional or Employment-Related Information

• Current or past job history
• Employment status and income information

2.8 Inferences Drawn from Other Personal Information

• Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Benefit eligibility assessments and recommendations

3. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you: When you provide information through our website, forms, or communications
• Automatically: Through cookies, web beacons, and other tracking technologies when you visit our website
• Third parties: From service providers, business partners, and other third parties who provide information about you
• Public sources: From publicly available sources such as government databases and public records

4. Business or Commercial Purposes for Collecting Personal Information

We collect personal information for the following business or commercial purposes:

• Providing our services: To match you with relevant benefit programs and provide connection services
• Customer service: To respond to your inquiries and provide support
• Communication: To send you important updates, newsletters, and promotional materials
• Personalization: To customize your experience and provide relevant recommendations
• Analytics and improvement: To analyze usage patterns and improve our services
• Legal compliance: To comply with applicable laws and regulations
• Security: To protect against fraud and ensure the security of our services
• Marketing: To send you promotional materials about our services (with your consent)

5. Categories of Personal Information We Disclose

In the past 12 months, we have disclosed the following categories of personal information for business purposes:

• Identifiers
• Personal information categories listed in the California Customer Records statute
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Professional or employment-related information
• Inferences drawn from other personal information

We disclose this information to the following categories of third parties:

• Service providers who assist us in operating our business
• Business partners who help us provide our services
• Government agencies when required by law
• Other third parties with your consent

6. Sale of Personal Information

We do not sell personal information of California residents. We do not sell, rent, or otherwise disclose personal information to third parties for monetary or other valuable consideration.

We may share personal information with service providers and business partners, but this sharing is not considered a "sale" under the CCPA because it is done for business purposes and not for monetary consideration.

7. Your Rights Under the CCPA

As a California resident, you have the following rights under the CCPA:

7.1 Right to Know

You have the right to request that we disclose to you:

• The categories of personal information we have collected about you
• The categories of sources from which we collected your personal information
• Our business or commercial purpose for collecting your personal information
• The categories of third parties with whom we share your personal information
• The specific pieces of personal information we have collected about you

7.2 Right to Delete

You have the right to request that we delete your personal information, subject to certain exceptions, such as when we need to retain the information to:

• Complete a transaction or provide a service you requested
• Comply with a legal obligation
• Detect security incidents or protect against fraudulent activity
• Engage in research in the public interest
• Enable internal uses that are reasonably aligned with consumer expectations

7.3 Right to Opt-Out of Sale

You have the right to opt-out of the sale of your personal information. However, as stated above, we do not sell personal information.

7.4 Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. We will not:

• Deny you goods or services
• Charge you different prices or rates
• Provide you a different level or quality of goods or services
• Suggest that you may receive a different price or rate or a different level or quality of goods or services

8. How to Exercise Your Rights

To exercise your CCPA rights, you can:

8.1 Submit a Request

You can submit a request by:

• Email: info@earnestbenefit.com
• Phone: Contact us through our website contact form
• Online: Complete our online request form (if available)

8.2 Verification Process

To protect your privacy and security, we will verify your identity before processing your request. We may ask you to:

• Provide information to verify your identity
• Confirm your request through a secondary method
• Provide additional documentation if necessary

8.3 Response Time

We will respond to your request within 45 days of receipt. If we need additional time, we will notify you and explain the reason for the delay. We may extend the response time by up to 90 days total if necessary.

8.4 Authorized Agents

You may designate an authorized agent to make a request on your behalf. The agent must provide proof of authorization and we may require verification of the agent's identity.

9. Minors Under 16

We do not knowingly collect personal information from minors under 16 years of age. If we become aware that we have collected personal information from a minor under 16, we will take steps to delete such information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

10. Changes to This Notice

We may update this CCPA Notice from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by:

• Posting the updated notice on our website
• Sending you an email notification (if you have provided your email address)
• Displaying a prominent notice on our website

Your continued use of our services after any changes to this notice constitutes your acceptance of the updated notice.

11. Contact Information

If you have any questions about this CCPA Notice or wish to exercise your rights, please contact us:

12. Additional Resources

For more information about the California Consumer Privacy Act, you can visit:

• California Attorney General's CCPA website
• California Privacy Rights Act website