CALIFORNIA CONSUMER PRIVACY ACT DISCLOSURES AND RIGHTS

THIS SUPPLEMENT APPLIES ONLY TO CALIFONIA USERS

This Privacy Policy for California Residents supplements the information already contained in Cornerstone Performance general Privacy Policy and applies solely to all users, visitors, and others who reside in the State of California.

Cornerstone Performance Privacy Policy for California Residents details the personal information that we may collect from you when you visit our website and make use of the Cornerstone Performance services. It also outlines the process for collecting, the purpose for which we use such data for, the sources from which we collect it, the limited circumstances under which we may share personal information, and provides you with specific choices and rights that you have as a California resident.

1. What is the CCPA?

The CCPA is a California law that provides California residents certain rights to their personal information. 

California residents, called “consumers” in the CCPA, have the following rights:

• The right to request that we disclose certain information to you about our collection and use of personal information over the past 12 months.
• The right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions.
• The right to opt-out of the sale of personal information by us.
• The right not to receive discriminatory treatment by us for exercising the privacy rights conferred by the CCPA.

We will explain more about how to exercise these rights below. 

2. Information We Collect

The personal information that Cornerstone Performance collects, or has collected from users within the last twelve months prior to the time of this disclosure becoming effective. Cornerstone Performance collects or has collected the following categories of personal information from its users:

• Personal identifiers such as your first name, last name, or similar identifier, address, phone numbers, or IP address;
• Internet or other electronic network activity information, including content interaction information, such as content downloads, search history and interaction data on your use of our website and from links in Cornerstone Performance emails sent to you;
• geolocation data, such as the location of your device or computer; and
• inference data, such as information about your purchase preferences, feedback and survey responses.

3. How We Collect Personal Information

Cornerstone Performance obtains the categories of personal information listed above from the following sources:

• Directly from our platform users when they provide the information to us.
• Indirectly from you, as you navigate through the website and engage with the services that we offer. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons, and other tracking technologies.
• From third-party service providers under service contracts.

4. Categories of Personal Information disclosed for Cornerstone Performance Business Purpose

The personal information that we disclosed about consumers for a business purpose in the twelve months prior to the effective date of this Disclosure fall into the following categories established by the California Consumer Privacy Act:

• identifiers such as your name, email address, phone number, or IP address;
• personal information, such as a credit card number, for example, if we use a third-party payment processor;
• geolocation data from your IP address.

5. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability:

You have the right to request that Cornerstone Performance disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and verify your request, we will 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 that personal information
• The specific pieces of personal information we collected about you (also called a data portability request)

6. Right to Request Access to or Deletion of Personal Information

You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by Cornerstone Performance, or access to or deletion of your personal information. But only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. Agents must submit proof that they have been authorized by the consumer to act on their behalf. 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. If you wish to do any of these things, please contact us. Depending on your data choices and subject to applicable regulations, certain services may be limited or unavailable.

We may, however, deny your deletion request if retaining the information is necessary for us or our service providers(s) to:

• Complete the purpose for which we collected the personal information, provide a 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.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• 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 et. seq. or other legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

7. No Discrimination Rights

You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA and Cornerstone Performance will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.