Privacy Notice for California Residents

Privacy for California Residents

This Privacy Notice for California Residents supplements the information contained in CalMTA’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to provide information about collection, use, and sharing of personal information and provide notice to consumers of their privacy rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice. In the event that this Privacy Notice conflicts with CalMTA’ general Privacy Policy, the terms of this Privacy Notice shall prevail.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

As provided more specifically in this Notice, the CCPA currently exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from certain of its requirements.

Information We Collect

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

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information otherwise excluded from the CCPA’s scope.

In particular, we may collect the following categories of personal information from users:

Identifiers.  For example, a real name, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).  For example, 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.

Protected classification characteristics under California or federal law.  For example, 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).

Commercial information. For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet activity or history or other electronic network activity information. For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet website or application.

Inferences drawn from other personal information. For example, profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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

• Directly from you. For example, from forms you complete for products and Services you wish to participate in and receive from us.
• Directly or indirectly through our Website. For example, from submission through our various Website portals.

Use of Personal Information

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to participate in our Service, we will use that information as needed to assist you with your participation in the program.
• To provide, support, personalize, and develop our Website, products, and Services.
• To personalize your Website experience and to deliver content and Service offerings relevant to your interests, including targeted content through our Website 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.
• 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 about our Website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to our third-party service providers for research or a business purpose, but only on behalf of CalMTA’s work. When we disclose personal information for a business purpose, we enter a contract that describes the service provider’s purpose for processing the personal information and which requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract.

We also share your personal information with:

• Analytics providers, unless you opt out
• Website hosting providers
• Subcontractors or consultants

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, CalMTA has 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 K: Inferences drawn from other personal information.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information, and, furthermore, do not have actual knowledge that we sell the personal information of consumers under 16 years old.

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, we will disclose to you, at your request:

• 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).
• The personal information categories disclosed for a business purpose that each category of recipient obtained.

These rights do not apply to B2B personal information.

Deletion Request Rights

You have the right to request that we delete 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 not complete or partially complete your deletion request if retaining the relevant information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.

These rights do not apply to B2B personal information.

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 completing the Data Rights Request form HERE.

Only you, or someone legally authorized 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, whether sent by you or your authorized agent, must:

• Provide sufficient information that allows us to reasonably work to verify that you are the person about whom we collected personal information or an authorized representative. To do so, we may ask that you provide additional 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 that certain the personal information relates to you.

Response Timing and Format

We will send an initial acknowledgement of receipt of your request within 10 business days upon our receipt of your request, at which point we may ask you to provide additional information. We will typically complete your 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 why 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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. 

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 post the updated notice on the Website and update the notice’s effective date. 

Contact Information

If you have any questions or comments about this notice, the ways in which CalMTA collects and uses your information described here, 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: (888) 217-0217 Email: [email protected]

Postal Address:
CalMTA (administered by Resource Innovations, Inc.)
719 Main Street, Suite A
Half Moon Bay, CA, 94019

(888) 217-0217