Privacy

Privacy Notice for California Residents

Last Updated 3/27/24

This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you").  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information").  In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

A. Identifiers.


B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).



C. Protected classification characteristics under California or federal law.


D. Commercial information.


F. Internet or other similar network activity.


H. Sensory data.


I. Professional or employment-related information.

Example

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.

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.


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).

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.


Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.


Audio, electronic, visual, thermal, olfactory, or similar information.


Information related to employment onboarding, including applications.

Personal information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.

Information excluded from the CCPA's scope, such as:

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.


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

Directly from our clients or their agents.  For example, from documents that our clients provide to us related to the services for which they engage us.

Directly from third parties with respect to such services, the information in the above documents.

Directly from you.  For example, from the information you provide us in connection with our performance of services on behalf of our clients or from information you provide to us related to employment.

Indirectly from you.  For example, from observing your communications on call monitorings or recordings, or interactions with computer systems and applications, in connection with the above services.

From third parties, including recruiters and employment agencies, who submit your information to us for an employment position that may interest you and consumer reporting agencies for employment background checks.


Use of Personal Information:

We may use, or disclose the personal information we collect for one or more of the following business purposes:

To fulfill the reason you provided the information.  For example, if you provide your personal information to make a donation, we will use that information to facilitate the processing of such donation; if you declined to make a donation, we will use that information to inform the client of same.

To carry out our obligations arising from any contracts entered into between our clients and us or our vendors and us. To process your requests, responses, and donations, and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To help maintain the safety, security, and integrity of our services, databases and other technology assets, and business.

As necessary or appropriate to protect the rights, property or safety of our clients, ourselves or others.

For testing, research, analysis, and product development, including to develop and improve our services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or for the establishment, exercise or defense of legal claims.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.



Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Our clients.

Third-party service providers.



Disclosures of 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 A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.  Records of donations made or considered, or other donation histories or tendencies.

Category F: Internet or other similar network activity.

H. Sensory data.

I. Professional or employment-related information.


We disclose your personal information for a business purpose to the following categories of third parties:

Our clients

Third-party service providers.


In the preceding twelve (12) months, we have not sold any personal information.



Your Rights and Choices

The CCPA provides consumers (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 Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 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.


Deletion Request Rights

You have the right to 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 (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) 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 service provider(s) to:

Complete the transaction for which we collected the personal information, provide the service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contracts.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

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 et. 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.

Comply with a legal obligation.

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Emailing us at:  info@telefund.com

Mailing us at:  Telefund, PO Box 120557, Boston, MA 02112

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, 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.


Response Timing and Format

We will acknowledge receipt of your request to know or deletion request within 10 days.  We will respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.



Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless

permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting

discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different

level or quality of goods or services.



Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice's effective date.  Your continued use of our website following the posting of changes constitutes your acceptance of such changes.



Contact Information

 If you have any questions or comments about this notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Emailing us at:  info@telefund.com

Mailing us at:  Telefund, PO Box 120557, Boston, MA 02112