California Privacy Policy for California Consumers

This privacy policy for California residents (the "CA Privacy Policy”) supplements the information contained in the Nossaman LLP general Privacy Policy (the “Privacy Policy”). This CA Privacy Policy only applies to those individuals or households who reside in California. We adopt this policy to comply with the California Consumer Privacy Act of 2018, known as CCPA, as amended by the California Privacy Rights Act of 2020, and any terms defined in the CCPA have the same meaning when used in this Policy.

This policy describes the personal information we collect, use, and disclose about individual clients, consumers, applicants, and contractors who visit or interact with this website, visit any of our offices, purchase or inquire about any of our products or services, contract with us to provide services, apply for a position of employment, or otherwise interact or do business with us.

This policy does not apply to our current and former partners and employees and their family members, dependents, and beneficiaries; if you are a California resident who is a current or former partner or employee of the Firm or a family member, dependent, or beneficiary of any of our current or former partners or employees, you may request access to our Employee Privacy Policy by sending an email to info@nossaman.com.

Your Rights Under the CCPA

The CCPA grants the following rights to all California residents who are natural persons:

Right to Know: you have the right to know what personal information Nossaman has collected, used, disclosed or sold in the last 12 months, both as to the categories and specific pieces of personal information.
Right to Delete: you have the right to request deletion of personal information held by Nossaman and, by extension, a service provider used by Nossaman.
Right to Limit; you have the right to limit the use and disclosure of sensitive personal information collected by Nossaman as defined by the CCPA.
Right to Correct: you have the right to request that we correct inaccurate information that we maintain about you, to the extent an inaccuracy exists;
Right to Opt-Out: California residents have the right to opt-out of the sale of personal information. Nossaman does not sell your personal information (as ‘sell’ is defined in CCPA) and therefore does not provide an opt-out option.
Right to Non-Discrimination: you have the right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.

Exercising Your Rights Under the CCPA

To exercise your right to know, correct, limit and delete information California residents must submit a verifiable request.

You can submit a request in two ways:

By calling toll-free (844) 529-1352
By emailing info@nossaman.com
By submitting an Online Form

As a resident of California, you may make a personal information request twice in a 12-month period. Nossaman will respond within 10 days to confirm receipt of the request and provide information on how the request will be verified and processed. Nossaman will provide a response to the request within 45 days of the verifiable consumer request.

Nossaman will not disclose, in response to a Request to Know, 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, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. Nossaman shall, however, inform you with sufficient particularity if we have collected this type of information.

Verifying Your Request

For Nossaman to respond to your Request to Know or Request to Delete, we must first verify your identity. Nossaman may use a third party verification service, or will request you submit verifiable information. The information you will be asked to provide depends on the type of request you make and the sensitivity of the information.

Generally, a Request to Know the categories of personal information held by Nossaman will require you to provide two types of verifiable consumer information. The same may apply to a Request to Delete. A Request to Know or Delete sensitive personal information may require you to provide at least three types of verifiable consumer information.

If Nossaman is unable to verify the identity of the requesting consumer, information will not be given and you will be notified of this reason for denial in Nossaman’s response.

Authorized Agent

If you are submitting a Request to Know or Request to Delete through an authorized agent, Nossaman will require you to provide the authorized agent written and signed permission to do so, verify their own identity directly with Nossaman, and directly confirm with Nossaman that they provided the authorized agent permission to submit the request. These requirements will not apply should you provide the authorized agent with a power of attorney.

Categories of Information Collected

Nossaman may collect personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

The following table lists the categories of personal information, as defined by the CCPA, that has been collected within the past 12 months, and how this information has been used and shared.

	Personal Information Categories and Examples	Source Categories	Purpose[s] for which the Information was Collected	Categories of Third-Party Sharing
1	Personal Identifiers such as name, 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.	Website information is collected from the website user or their connected device while they are interacting with our website. Contact information is collected directly from an individual, website user, client or other contact.	Website information is used to improve our web-based offerings and website functionality. Tracking movement within our website allows us to better understand user preferences and enhance our user interface. Contact information is used to provide services to our clients or website users, perform contracts, marketing communications, protect against fraud or illegal activity, and business operations.	All data collected from our website is stored in a third-party-hosted database with cloud storage. This database is only accessed by Nossaman and its third-party website development team. Website information is shared with our website analytics service providers. Contact information is shared with third parties when it’s necessary to provide a service and at the consent of the consumer. This information may also be shared with our business operation and business software providers.
2	Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as bank account number, credit card number, debit card number, or any other financial information, medical information, health insurance information, Social Security number, physical characteristics or description, passport number, driver’s license or state identification card number, insurance policy number, education, employment, or employment history.	This information is collected through client and employee background and verification checks, electronic communications, intake paperwork completed during the course of business, regular accounting procedures conducted during the course of business, and the pursuance of employment opportunities.	This information is used to provide services to our clients, perform contracts, marketing communications, protect against fraud or illegal activity, to employ staff members, and business operations.	Financial information is shared with our business operation providers to complete a sale or purchase of a service at the consent of the consumer.
3	Protected classification characteristics under California or federal law, such as 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, or veteran or military status.	This information may be collected through client and employee background and verification checks, electronic communications, intake paperwork completed during the course of business, and the pursuance of employment opportunities.	This information may be used to provide services to our clients, perform contracts, protect against fraud or illegal activity, and to process employee intake forms required by the state and federal government.	Information given on employee forms will be shared with the state and federal government, as required by law.
4	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	This information is collected via electronic communications, submission of forms on this website, intake paperwork completed during the course of business, and regular accounting procedures conducted during the course of business.	This information is used to provide services to our clients, enhance web-based offerings, perform contracts, marketing communications, protect against fraud or illegal activity, and in business operations.	This information is shared with third parties when it’s necessary to provide a service and at the consent of the consumer. This information is also shared with our business operation and business software providers.
5	Biometric information, such as fingerprint technology.	This information is not regularly collected during the course of business; however, it may be used in the duration of employment for authentication (fingerprint/facial recognition technology).	This information may be used in business operations for employees to securely access computers, tablets or phones.	We do not share this information.
6	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. Employee interaction with an external website.	This information is collected directly or automatically from consumers through their interaction with our website Employee information is collected when an employee browses external websites while logged into our internal network.	This information is used to improve our web-based offerings and website functionality. Tracking movement within our website allows us to better understand user preferences and enhance our user interface. Employee data is collected for security purposes.	Consumer information is shared with our website analytics service providers. Employee information may be shared with our business operation and business software providers.
7	Geolocation data.	This information is collected directly or automatically from consumers through their interaction with our website.	This information is used to improve our web-based offerings and website functionality.	This information is shared with our website analytics service providers.
8	Audio, electronic, visual, thermal, olfactory, or similar information.	This information may be collected during the course of business through electronic communications or recording devices.	This information is used to provide legal services to our clients and educational program participants.	Video and audio may be shared as a part of normal business operations.
9	Professional or employment-related information.	Defined above in rows one, two, three and five.	Use of information explained above in rows one, two, three and five.	We may share this information as explained above in rows one, two, three and five.
10	Education Information, defined as 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).	This information is collected through client and employee background and verification checks, electronic communications, submission of forms on this website, intake paperwork completed during the course of business, regular accounting procedures conducted during the course of business, and the pursuance of employment opportunities.	This information is used to provide services to our clients, perform contracts, marketing communications, protect against fraud or illegal activity, to employ staff members, and business operations.	This information is shared with third parties when it’s necessary to provide a service and at the consent of the consumer. This information is also shared with our business operation and business software providers.
11	Inferences drawn from other personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities or aptitudes.	This information is collected directly or automatically from consumers through their interaction with our website.	This information is used to improve our web-based offerings and user interface.	This information may be shared with our website development team and website analytics service providers.

Retention of Your Information

Nossaman will retain your personal information for so long as required to provide the services or complete the transactions for which your personal information was collected. Nossaman will also retain data for as long as legally required or allowed to do so for compliance obligations, dispute resolutions and pursuant to Nossaman policies or contractual obligations.

Shine the Light

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from Nossaman once a year, free of charge, information about their personally identifiable information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year, if at all. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared such information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:

Nossaman LLP
Attn: Chief Business Development Officer
777 South Figueroa Street, 34th Floor
Los Angeles, CA 90017

Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to a consumer request once during any calendar year.

How to Contact Nossaman for Information

If we need to contact you, we will do so by any available method, including by e-mail sent to the e-mail address provided by you. You must notify us if you change your e-mail address or other contact information.

If you wish to contact us for any further information, please send an e-mail to info@nossaman.com.