California Consumer Privacy Act
RIGHTS PURSUANT TO THE CALIFORNIA CONSUMER PRIVACY ACT (the "CCPA")
California law requires certain businesses to disclose information regarding the rights of California residents pursuant to the CCPA.
A California resident may request that Steptoe LLP ("Steptoe") disclose to you the following information covering the preceding 12 months:
(1) The categories of personal information Steptoe has collected about you;
(2) The categories of sources from which the personal information was collected;
(3) The business or commercial purpose for collecting or selling personal information;
(4) The categories of third parties with which Steptoe shares personal information;
(5) The categories of personal information about you that Steptoe sold and the categories of third parties to which the personal information was sold;
(6) The categories of personal information about you that Steptoe disclosed for a business purpose and the categories of third parties to which the personal information was disclosed;
(7) The specific pieces of personal information Steptoe has collected about you.
A California resident may request the disclosure of the information listed above by calling +1 866 363 1874 or submitting a request here. Such a request may be referred to as a right to know request. Pursuant to California law, Steptoe will verify the California resident's identity before complying with any such request.
A California resident has the right to request that Steptoe delete any personal information about the California resident that it has collected from the California resident, and that Steptoe direct any service provider to delete the California resident's personal information from its records. Such a request may be referred to as a request to delete. However, pursuant to the CCPA, your information may not be deleted under certain circumstances, including where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with Steptoe, or to otherwise perform a contract between Steptoe and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Steptoe; to comply with a legal obligation; or to otherwise use your information internally in a lawful manner that is compatible with the context in which you provided the information. For more information about these and other situations in which we may not delete your information, please see Cal. Civ. Code Section 1798.105(d). A California resident may request the deletion of information collected about the California resident by calling +1 866 363 1874 or submitting a request here. Before deleting your personal information, Steptoe will verify your identity and confirm your request, as required by the CCPA.
A California resident may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent, the California resident must provide the agent with written authorization. In addition, the California resident may be required to verify their own identity with Steptoe. Steptoe may deny a request from an agent that does not submit proof that they have been authorized by the California resident to act on their behalf. Such requirements, however, will not apply where a California resident has provided the authorized agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.
A California resident has the right, at any time, to direct Steptoe not to sell their personal information. This right may be referred to as the right to opt-out. You may opt out of the sale of your personal information at a dedicated webpage entitled "Do Not Sell My Personal Information" or by calling +1 866 363 1874 and/or emailing privacy@steptoe.com. If Steptoe has a good faith, reasonable, and documented belief that a request to opt-out is fraudulent, it may deny the request. A California resident may use an authorized agent to submit a request to opt-out on the California resident’s behalf. The California resident must provide the agent with written authorization do so. Steptoe may deny a request from an agent that does not submit proof that they have been authorized by the California resident to act on the California resident's behalf.
In addition, Steptoe does not and will not sell the personal information of a California resident it has actual knowledge is under the age of 16 without affirmative authorization (known as "opt-in").
Steptoe will not discriminate against a California resident because the California resident exercised any of their rights under the CCPA, including, but not limited to, by:
(1) Denying goods or services to the California resident;
(2) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
(3) Providing a different level or quality of goods or services to the California resident;
(4) Suggesting that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, Steptoe may charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to Steptoe by that resident's data. In addition, Steptoe may offer financial incentives, including payments to California residents as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. Steptoe may also offer a different price, rate, level, or quality of goods or services to the California resident if that price or difference is directly related to the value provided to Steptoe by that resident’s data. Steptoe will notify California residents of such financial incentives. Steptoe will enter a California resident into a financial incentive program only if the California resident gives Steptoe prior opt in consent which clearly describes the material terms of the financial incentive program, and which may be revoked by the California resident at any time. Steptoe will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
In the preceding 12 months, Steptoe has collected the following categories of personal information about California residents from the following sources and for the following purposes. The CCPA requires that Steptoe reference specific categories of personal information enumerated in the CCPA. Steptoe may collect only certain pieces of personal information described in a given category and may not collect certain pieces of personal information described in each category.
In the preceding 12 months, Steptoe has sold the following categories of personal information about California residents to the following categories of third parties.
In the preceding 12 months, Steptoe has disclosed for a business purpose the following categories of personal information about California residents to the following categories of third parties (to the extent the disclosure was made to a third party).