Privacy Notice – CCN Global

Communications Consultancy Network

Privacy Notice

Last Updated July 2023

PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice (“Privacy Notice”) sets out how Communications Consultancy Network (herein referred to as “CCN”, “we”, “us” or “our”) processes your personal information in connection with our business, including the provision of our website (“Site”) and the services we offer (“Services”).

Additionally, this Privacy Notice explains our approach to any personal information that we might collect from you (i) when you use our Site or Services (ii) during any other interactions with us, or (iii) which we might otherwise process when providing Services to our clients (including the personal information we collect, why we collected it and your rights in respect of our processing of your personal information).

This Privacy Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Cookie Notice.

If you are a California consumer and would like information about our online and offline privacy practices and your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement” by clicking here.

Please note that a separate notice applies to our processing of personal information in the European Union and the United Kingdom. To view our EU/UK Privacy Notice please click here.

SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice only applies to the use of your personal information obtained by us, whether from you directly or from a third party. It does not apply to personal information collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links on our Site to third party websites over which we have no control).

Further, this Privacy Notice is not intended to cover the processing of workplace personal information. Accordingly, if you are engaged as a worker for us, please see our Workplace Privacy Notice which sets out further information about how we may process your personal information in connection with your employment and/or engagement.

CHANGES TO THIS NOTICE

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal information, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal information. If we update this Privacy Notice, we will update the ‘Last Updated’ date at the top of the page.

ABOUT US

The Site and Services are made available by Communications Consultancy Network.

HOW TO CONTACT US

If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:

Email	Send us an email at: [email protected]
Post	Write to us at: Communications Consultancy Network 1285 6th Ave, New York, NY 10019, USA

TYPES OF PERSONAL INFORMATION WE COLLECT/PROCESS

When we talk about personal information, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. Categories of personal information we may collect and process about you include:

Identity Data	First name; last name.
Contact Data	Delivery address; billing address; email address; telephone number; social media handle.
Applicant Data	Date of birth; gender; country; nationality; resumes, work experience; dietary requirements any other personal information that you may provide in advance of/during your supply of services to us.
Image Data	Photos; video recordings.
Financial Data	Bank account details; partial payment card details.
Transaction Data	Details about payments made between you and us; details of services purchased from us.
Profile Data	Interests and preferences; contact/marketing preferences; feedback and survey responses.
Behavioral Data	Data relating to your browsing activity, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any services you viewed or purchased through the Site.
Technical Data	IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Publicly Available Data	Information about articles (or similar) that you may have published; information about your interests or affiliations or publicly stated positions on political matter, corporate matters and similar.

For more information about the personal information we collect please refer to section ‘HOW WE USE PERSONAL INFORMATION‘ below.

HOW WE COLLECT PERSONAL INFORMATION

We may collect and receive your personal information using different methods:

Personal information you provide to us	You may give us your personal information directly, for example, when you obtain services via our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
Personal information we collect using cookies and other similar technologies	When you access and use our Site, we may collect certain Behavioral Data and Technical Data. We collect this personal information by using cookies and other similar technologies (see the ‘Website insight and analysis‘ section below).
Personal information received from third parties	We may receive personal information about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services.
Publicly available personal information	From time to time, we may collect personal information about you (Identity Data, Contact Data, or Publicly Available Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

WHO WE COLLECT PERSONAL INFORMATION ABOUT

We collect and process personal information from the following people:

Site visitors	We will collect and process your personal information in connection with your interaction with us and our Site.
People who contact us with enquiries	If you contact us with an enquiry through our Site, submit a complaint or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal information in connection with your interaction with us and our Site.
Client personnel	We may collect and process your personal information in connection with the supply of services to you and/or your organization.
Talent	If you supply services and/or content to us and/or work with us to provide services to our client (including featuring in content we produce), we may collect or process your personal information, such as your Identity Data, Contact Data, Financial Data, and Resumes in connection with such supply of services and/or content to us and our clients.
Partner/supplier personnel	If you (or your organization) supply products or services to us or otherwise partner with us, we may collect and process your personal information in connection with our receipt of those products and services and/or partnership. This may include personal information included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.
Visitors to our offices or other locations	If you attend one of our physical offices or other locations, we may process personal information that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal information when signing in as a guest, or when you register for and access our guest Wi-Fi network at our premises. CCTV footage may also be collected for security purposes.
Event attendees	If you attend one of our events, we will process personal information about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other documents relating to the event.
Job applicants	If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal information in connection with your application.
Members of the public	We may process your personal information in connection with the provision of the Services to our clients.

HOW WE USE PERSONAL INFORMATION

OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING

Operation of the Site

If you browse our Site

When you browse our Site, we may collect and process Behavioral Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.

Website insight and analysis

We and our third-party partners might use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site. The data that is collected could include Behavioral Data and Technical Data, and certain Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners.

We and our third-party partners use this data to analyze how you use our Site and our Services and the effectiveness of our Site and Services, including:

to analyze how you use, and the effectiveness of, our Site and Services;
to count users who have visited our Site and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and Services;
to measure the effectiveness of our content;
to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
to help us understand the type of marketing content that is most likely to appeal to our visitors and customers.

If you use the interactive features on our Site

We will collect and use personal information about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use the Enquiry Form or Chat function to get in touch with us or other account holders, or so that you can be searched for by other account holders.

If you link to social media sites and interact with our social media pages

If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal information in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal information, please see the ‘Website insight and analysis’ section above.

The relevant social media platform may also be a controller in respect of the personal information that is collected via your use of our social media pages and may use that personal information for additional purposes. For details of how the relevant social media platform uses your personal information, please see the privacy notice of the relevant social media platform.

Provision of our Services

Provision of client facing services

We may, acting on our own behalf and on behalf of our clients, collect personal information (including the types of personal information we set out in Section 6 in the ‘Types of personal information we collect/process‘ about you in connection with the provision of our Services.

Social media

We may collect or process individuals’ personal information (including Contact Data, Identity Data and some Profile and Publicly Available Data) who engage with us through our social media channels (including by visiting our social media pages or otherwise communicating with us via social media). We may also operate our client’s social media pages, accounts or channels acting on their behalf.

Marketing and Media Enquiries

Marketing

We may use your Identity Data, Contact Data and Profile Data to send you (or the organization you represent) marketing communications by email or via phone. Our marketing may include press releases and information about us.

Media and informational inquiries

We may collect personal information (including Identity Data, Contact Data and Publicly Available Data) about journalists, client contacts or industry contacts for interviews requests, for media questions, or requests for information about CCN. We may also provide individuals with the opportunity to sign up for newsletters or to receive copies of blogs and other information that we make available. Where an individual signs up to receive such information, Contact Data may be requested in each case, together with details of other personal information that is relevant to these inquiries. This information is used in order to enable us to respond to individual requests or media requests.

Events

From time to time, we may organise and host road shows and other industry events to promote our services or on behalf of clients. For this purpose we may process data including Identity Data and Contact Data (including email address, postal address and telephone number) to communicate with them about such events where they have specifically requested information about such events or where we have another lawful basis for sending that information to them.

If you attend one of our events, we may use your personal information to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary or other requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications we send to our clients and/or publish on our Site, in print or other media.

BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL

Receipt of services

If we have engaged an organization to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal information (including Contact and Identity Data) if you are a contact within the relevant organization in order to manage our relationship or our clients with the organization, to receive services from the organization and, where relevant, to provide our services to others including our clients.

Recruitment

If individuals apply for a job with us or otherwise express an interest in working for us, we will collect contact details and CV or resume information from the individual. We use such personal information for the following purposes: a) to assess the individual’s suitability for any position for which they applied (or future positions for which we think the individual may be suitable) including employment or freelancer positions, summer placements or internships and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application; b) to take any steps necessary to enter into any contract of employment (or otherwise) with the individual; c) to comply with any regulatory or legal obligations in relation to any such application; and d) to review our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.

Visiting our premises, studios or production sites

If an individual visits any of our premises, studios and/or production sites we may collect personal information including Identity or Contact Data as part of our sign in process. We may also capture their image on our surveillance camera or CCTV.

If an individual registers as a guest user for free Wi-Fi access at any of our premises, we may collect personal information including Identity and Contact Data as part of the registration process. We may also process Behavioral and Technical Data in connection with any use of this free Wi-Fi service for monitoring and record-keeping purposes, including to identify the source of service requests, optimize and maintain performance of the Wi-Fi service, and investigate and prevent system abuse.

Business administration, finance, and legal compliance

We may use an individual’s personal information (including Identity Data, Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the following business administration and legal compliance purposes:

to facilitate the operation or effective management of our group of businesses;
for financial, accounting and tax purposes;
to comply with our legal obligations;
to enforce or protect our legal rights;
to deal with complaints;
to protect the rights of third parties (including where health or security of an individual is endangered (e.g. a fire); and
in connection with a business transition or sale such as a merger, re-organization, acquisition by another company, or sale of all or a portion of our assets.

IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information that we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

SHARING YOUR PERSONAL INFORMATION

We only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations.

We may share data (subject to the above) with our partner agencies and other Omnicom Group companies. For more information about the Omnicom Group, please see here: Advertising and Marketing Agencies | Omnicom Group

Further (again subject to the above) we may share your personal information with third parties as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties.

Our Clients	We may share personal information with our clients for the purposes of providing them with Services.
Our specialist suppliers/partners	We use various specialist suppliers including external subject matter experts and/or partners in order to provide our services including, communications, promotions and events.
Third-party IT suppliers	We may share personal information with third parties who support us in providing our Site and help provide, run, and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centers around the world, and personal information may be stored in any one of them. We may also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Notice.
Payment providers and banks	We may share personal information with third parties who assist us with our invoicing and/or making/receiving payments.
Third-party post/email marketing and CRM specialists	We may share personal information with specialist suppliers who assist us in managing our marketing database and sending out email marketing communications.
Recruitment agencies and related organizations	We may share personal information with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies for recruitment purposes
Auditors, lawyers, accountants and other professional advisers	We may share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies	We may share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
Other third parties	Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

ONWARD TRANSFERS

As we are a company based in the United States you acknowledge and agree that any data that is provided directly to us may be stored in the United States. We may also transmit your personal information to other third parties outside of the United States (as listed above in ‘SHARING YOUR PERSONAL INFORMATION‘ and more specifically to the offices of other global Omnicom Group entities, networks or partners agencies.

OBTAINING YOUR CONSENT

Where our use of your personal information requires your consent, you can provide such consent:

at the time that we collect your personal information following the instructions provided; or
by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal information under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal information on our behalf) are obliged to respect the confidentiality of the personal information of all users of our Site and those who purchase our Services.

ACCESS

To the extent required by applicable law, we will provide you with reasonable access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where permitted by law (such as where the burden or expense of providing access would be disproportionate or where the rights of third parties would be violated).

You may exercise these rights verbally or in writing by using our contact information provided in the section entitled ‘HOW TO CONTACT US‘ above. We will endeavor to promptly respond to your requests and will respect time frames set by local legislation where applicable.

Please note that in order for you to assert these rights we may need to verify your identity to confirm your right to access your personal information. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal information from you than we currently have.

OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other commercial communications from us, you should send a request to us at the contact information in the section entitled ‘HOW TO CONTACT US‘ above.

ENFORCEMENT RIGHTS AND MECHANISMS

We will ensure that this Policy is observed and duly implemented. If at any time you believe that your personal information has been processed in violation of this Policy, or if you have any inquiries or complaints about the use or limitation of use of your personal information, you may send a request to us at the contact information in the section entitled ‘HOW TO CONTACT US‘ above.

THIRD PARTY LINKS AND SERVICES

This Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies to these third-party websites and third-party service providers unless we are acting as joint controllers in respect of your personal information with such third party.

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is necessary for the purposes described in this Privacy Notice, after which it is deleted from our systems.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will delete it at the end of that period. Please note that if you are an unsuccessful candidate, we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list so that we know not to send you further marketing communications in the future.

PERSONAL INFORMATION OF MINORS

Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal information of minors. However, due to the nature of our organization and the Services we provide, we may from time-to-time collect and process personal information relating to minors. If we do collect personal information of minors, we will comply with all applicable laws and regulations relating to the processing of personal information of minors.

COUNTRY SPECIFIC PROVISIONS

UNITED STATES

California Consumer Privacy Statement

Last Updated: 1st March 2023

This California Consumer Privacy Statement (“Statement”) supplements the CCN Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to CCN personnel. Sections 2-5 of this Statement do not apply to job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

Identifiers:identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Sensory Information:audio, electronic, visual, and similar information
Employment Information:professional or employment-related information
Education Information:education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our online Privacy Notice and for the following business purposes specified in the CCPA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Managing career opportunities with CCN.

Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

Directly from you, such as when you contact us with a question or comment
From your devices, such as when you visit our Site
Vendors who provide services on our behalf
Social networks
Government entities
Data brokers

Sale of Personal Information

We do not and will not sell your personal information.

Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information	Category of Third Party
Identifiers	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Additional	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Protected Classifications	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Commercial	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Online Activity	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Employment Information	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Education Information	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks
Inferences	Our affiliates and subsidiaries; Vendors who provide services on our behalf; Professional services organizations, such as auditors and law firms; Our business partners; Advertising networks; Internet service providers; Data analytics providers; Operating systems and platforms; Social networks

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: Government entities.

California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request (or to submit a request as an authorized agent on behalf of a consumer), email us at the address provided in the section entitled ‘HOW TO CONTACT US’ above. For questions or concerns about our privacy policies and practices, please contact us as described in the section entitled ‘HOW TO CONTACT US‘ above.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: your email address, the name of the CCN representative with whom you typically interact, and the date of your last interaction with a CCN representative. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.