Last Updated: August 26, 2020

This California Consumer Privacy Statement supplements the Privacy Policy. It applies solely to California consumers and addresses personal information we collect online and offline.  This Statement does not apply to personal information about HPS employees and other personnel.  In addition, this Statement does not apply to nonpublic personal information we obtain subject to the Gramm-Leach-Bliley Act (“GLBA”). 

This California Consumer Privacy 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”).

1. 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 and physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial 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, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of services obtained 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
• 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 U.S. 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
  
  

2. 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 email us
• Your devices, such as when you visit our Site
• Individuals, such as your friends or colleagues, who provide us with your contact information so we can send information that may interest you
• Our affiliates
• Vendors who provide services on our behalf
• Social networks
• Government entities
  
  

3. Sale of Personal Information

We do not sell your personal information in exchange for monetary or other valuable consideration.

4. 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:

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.

5. 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 may 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, please email your request to privacy@hpspartners.com, fill out this form, or call us at (833) 457-0279. 

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 contact or other identifying information, as well as information about your recent business interactions with HPS.  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.  If you designate an authorized agent to make an access or deletion request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) we may require you to verify your own identity directly with us (as described above).  To submit a request as an authorized agent on behalf of a consumer, please contact us as described above under “How to Submit a 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.