CPRA Privacy Notice
Last Updated: January 19, 2023
Information We Collect
We collect personal information. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|1. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.|
|2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||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.|
|3. Protected classification characteristics under California or federal law.||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).|
|4. Commercial information.||Information you provide when you interact with us and our website, and information about the products or services we sell or provide to you.|
|5. Geolocation data.||The geographic location of your mobile device and the boundaries and name of your field|
|6. Professional or employment-related information.||Current or past job history or performance evaluations.|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CPRA’s scope, like:
- 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;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Use of Personal Information
We may use each of the categories of personal information described above for one or more of the following purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and accurately provide you with the information you are seeking. For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our employee, customers or others.
- 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 CPRA.
- 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 is among the assets transferred.
We use or disclose sensitive personal data for the following purposes only: providing the products and services you request, as well as improving those offerings; operating and overseeing our business; protecting rights and interests; short-term transient uses; and for purposes that do not infer characteristics about consumers.
We retain the categories of information described above for so long as reasonably necessary and proportionate to fulfill the business purposes set out above. The criteria that inform our retention practices include legal requirements, contractual requirements, and business needs. For example, we will retain your information during ongoing interactions with you, including pending inquiries about sales and services, events and training registrations, and other matters, and for a reasonable period thereafter to enable any follow up of our correspondence and contact if needed.
Disclosure of Personal Information
In the preceding twelve (12) months, we have not sold or shared for cross-context behavioral advertising any personal information. We also have not knowingly sold or shared for cross-context behavioral advertising personal information for minors less than sixteen (16) years of age.
We may disclose your personal information for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category 1: Identifiers.
Category 2: California Customer Records personal information categories.
Category 3: Protected classification characteristics under California or federal law.
Category 4: Commercial information.
Category 5: Geolocation data.
Category 6: Professional or employment-related information.
We disclose your personal data as follows:
- To, for example, improve our offerings, our Affiliates may receive the information we collect directly from our employees, customers or their agents; indirectly from our employees, customers or their agents; directly and indirectly from activity on our website; and from third-parties that interact with us in connection with the services we perform.
- To provide certain services, our vendors and business partners may receive the information we collect directly from our employees, customers or their agents; indirectly from our employees, customers or their agents; directly and indirectly from activity on our website; and from third-parties that interact with us in connection with the services we perform. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
We may disclose all of the information we collect to protect rights and interests or with your consent. Categories of Sources
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our employees, customers or their agents. For example, from documents that our customers provide to us related to the services for which they engage us.
- Indirectly from our employees, customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Your Rights and Choices
The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.
Consistent with applicable law, you may request notice of and access to certain information about our collection and use of your personal information.. Once we receive and confirm your verifiable consumer request, we may disclose to you:
- 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 or selling 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). If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You may request that we correct personal information about you that is inaccurate. You may request that we delete any of 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 or de-identify (and direct our vendors to delete or de-identify) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our vendors 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.
- Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes.
- 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 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 and compatible with the context in which you provided the information
- Comply with a legal obligation.
Exercising Your Rights
To exercise the access, data portability, deletion, and correction rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 1-888-988-6177
- Visiting Wilbur-Ellis Privacy Request Form
Only you or an authorized agent 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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- 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 the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will not discriminate against you for exercising any of your CPRA rights, although some of the functionality and features available on the service may change or no longer be available to you. Any difference in the services is related to the value provided.
Changes to Our Privacy Notice
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
345 California Street, 27th Floor San Francisco, CA 94104
Attn: General Counsel