Privacy Notice and Disclosure for California Residents

Effective August 1, 2023

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of Reliance Worldwide Corporation Ltd., as well as the privacy policies of any of its affiliates or subsidiaries, as applicable (hereinafter “RWC”, “we”, or “us”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopted this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") as amended by the Consumer Privacy Rights Act (“CPRA”) and as it may further amended from time to time . Unless otherwise defined, any terms defined in the CCPA have the same meaning when used in this notice.

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: (a) information that is publicly available from government records; (b) de-identified or aggregated consumer information; or (c) information excluded from the CCPA's scope, such as (i) 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; or (ii) personal information covered by sector-specific privacy laws including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“CalFIPA”), or the Driver’s Privacy Protection Act of 1994.

The following table and associated statement includes disclosures of the personal information we collect from consumers and the purposes for which it is collected and used, as well as lists of categories of consumers’ personal information we have collected about consumers in the past 12 months, the categories of sources from which it was collected and categories of third parties with whom we shared the personal information.  These disclosures are made pursuant to the CCPA and supplement any other disclosures or notices found in our general privacy policy, cookie policy, or other statements contemporaneously or previously given or made available to you.

In the past twelve (12) months, RWC has disclosed personal information to service providers for business or commercial purposes. The categories of personal information we have disclosed to service providers for business or commercial purposes include:

• Internet and other network activity information
• Personal identifiers, such as name, title, biographical information (from other sources in the course of our business), social media identifiers, physical address, IP address, email address, or other, similar identifiers.

This information is collected and used for the purposes disclosed in this Privacy Notice and the General Privacy Policy.

Aside from disclosures to service providers, the CCPA also requires that RWC disclose “sales” of personal information to third parties. The CCPA further requires businesses that “sell” personal information (as the term “sell” is defined under the CCPA) to provide an opt-out from such sales.  Some people have taken the position that when a website or app uses third-party cookies and similar technology for its own analytics or advertising purposes, the website/app is engaged in a “sale” under the CCPA if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app.  Some take this position even when the website/app pays the third party (not vice versa), and in most cases merely provides the third party with an opportunity to collect data directly, instead of providing personal information to the third party. 

RWC does not believe that any of its activities with service providers constitute “sales” under the CCPA and currently available guidance.  However, if you take the position that any of the relationships described above involve a “sale” within the meaning of the CCPA, then you may consider RWC to have “sold” what the CCPA calls “identifiers” (like IP addresses), “internet or other electronic network activity information” (like information regarding an individual’s browsing interactions on www.rwc.com or affiliate sites), and “commercial information” (like the fact that a browser visited a page directed to people who are considering purchasing from us) to those service providers. As we await clarity, we continue to offer opportunities to limit and/or opt out of the collection and/or use of data via certain third-party cookies and similar technology for analytics and advertising purposes, as described in the paragraph below.

To learn more about interest-based advertising, including how to opt out from the targeting of interest-based ads by some of our current ad service partners, visit aboutads.info/choices  or youronlinechoices.eu from each of your browsers on each of your devices.  You can opt out of Google Analytics and customize the Google Display Network ads by visiting the Google Ads Settings page and installing the Google Analytics Opt-out Browser Add-on from each browser on each device.  If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again.  We do not monitor or follow “Do Not Track” (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Policy.  Please visit your mobile device manufacturer's website, or the website for its operating system, for instructions on any additional privacy controls in your mobile operating system, such as privacy settings for device identifiers and geolocation.

You may be able to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent.  Some browsers offer similar settings for HTML5 local storage, and Flash storage can be managed as described here.  

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purpose for collecting their personal information, and the categories of third parties with whom we shared their personal information. You may submit a request to know by following the process outlined in Section D below.

California residents have the right to request deletion of the personal information we have collected from them, subject to certain exceptions set forth within the CCPA.  You may submit a request to delete by following the process outlined in Section D below.

We may deny your deletion request if we are unable to verify the request or 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 good 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.
• 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 et. 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 a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Except to the extent we may deny your request above, we shall otherwise make reasonably best efforts to retrieve and delete any personal information associated with or linked to you.  We shall also reach out to any third party vendors and other service providers with whom we may have shared your personal information to request deletion and confirmation of the same. 

California residents have the right to request correction of inaccurate personal information. You may submit a request to correct inaccurate personal information by following the process outlined in Section D below.

We will use all reasonable efforts to fulfill any correction request. When a request is received, we will evaluate the request using the totality of the circumstances and relevant documents in order to correct any inaccurate information.

You can submit a request exercising your right to know, delete, or correct by visiting the following link or by calling 1-844-924-0069.  You will need to provide us with personal information to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purposes. We do not discriminate against California residents who exercise their privacy rights under CCPA.

Once we properly verify your request, we will send you an acknowledgement letter via email or mail describing our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

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 via email or mail why we made that decision and provide you with a cost estimate before completing your request.

Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

Submitting Requests via an Authorized Agent: Only you, a person registered with the California Secretary of State, or a person you authorize 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. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465.  If a power of attorney that meets those provisions is not submitted, you will be required to verify your identity directly by submitting a verified consumer request according to the procedures outlined above.  If anyone purporting to be an authorized agent for a consumer contacts us, we will require proof that the authorized agent has been authorized to act on the consumer’s behalf.

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 (e.g., rewards programs) permitted by the CCPA that can result in different prices, rates, or quality levels. If so, any CCPA-permitted financial incentive we offer will reasonably relate to your provided 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.

We may update and make changes to this Policy to reflect any changes to our information practices.  If we make any material changes, we will notify you in accordance with applicable law. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review our website for the latest information on our privacy practices.

If you have questions or concerns about our privacy policy or practices, please contact us immediately as set out below:

Mail:

RWC Privacy
Attn: CCPA Request
2300 Defoor Hills Rd. NW
Atlanta, GA 30318
United States

Phone:

1-844-924-0069

Email:

[email protected]
[email protected]
[email protected]