USA Privacy Addendum

1.       Commitment and Scope

1.1       This U.S. Privacy Addendum supplements the information contained in the Global Privacy Policy and our Fair Processing Notice.

1.2       Charles Taylor complies with the requirements of the prevailing data protection legislation with regard to the collection, storage, processing and disclosure of personal information and is committed to upholding the core data protection principles.

1.3         For those who work for Charles Taylor in the USA, the Charles Taylor Employee Privacy Notice is accessible online via our intranet.

2.           Colorado residents

2.1       If you are a Colorado resident for whom we collect personal information as a controller under the Colorado Privacy Act (CPA), you may rely on the disclosures in our Global Privacy Policy and Global Fair Processing Notice.

2.2       Under the CPA you are afforded the following rights regarding your personal information:

• Right to access
• Right to correction
• Right to deletion
• Right to portability

2.3       In addition to the applicable rights outlined above, you may exercise your right under the CPA to opt out of the sale of personal information by emailing us at dpo@charlestaylor.com

2.4       Charles Taylor does not process your personal information for targeted advertising purposes or carry out profiling on you or your behavior and/or habits. You will not be discriminated against for exercising any of your data rights.

3.       Connecticut residents

3.1       If you are a Connecticut resident for whom we collect personal information as a controller under the Connecticut Data Privacy Act (CTDPA), you may rely on the disclosures in the Global Privacy Policy and Global Fair Processing Notice.

3.2       Under the CTDPA you are afforded the following rights regarding your personal information:

• Right to access
• Right to correction
• Right to deletion
• Right to obtain a copy

3.3         In addition to the applicable rights outlined above, you may exercise your right under the CTDPA to opt out of the sale of your data and profiling that may have a legal or other significant impact. To opt out email dpo@charlestaylor.com

3.4       Charles Taylor does not process your data for targeted advertising purposes or carry out profiling on you or your behavior and/or habits. You will not be discriminated against for exercising any of your data rights.

4.       Utah residents

4.1       If you are a Utah resident for whom we collect personal information as a controller under the Utah Consumer Privacy Act (UCPA), you may rely on the disclosures in the Global Privacy Policy and Global Fair Processing Notice.

4.2       Under the UCPA you are afforded the following rights:

• Right to access
• Right to deletion
• Right to portability

4.3       In addition to the applicable rights outlined above, you may exercise your right under the UCPA to opt out of the sale of personal information processed by emailing us at dpo@charlestaylor.com

4.4       Charles Taylor does not process your data for targeted advertising purposes or carry out profiling on you or your behavior and/or habits. You will not be discriminated against for exercising any of your data rights.

5.       Virginia residents

5.1       If you are a Virginia resident from whom we collect personal information as a controller under the Virginia Consumer Data Protection Act (VCDPA), you may rely on the disclosures in the Global Privacy Notice and the Global Fair Processing Notice.

5.2       Under the VCDPA you are afforded the following rights:

• Right to know, access and confirm personal data
• Right to delete personal data
• Right to correct inaccuracies in personal data
• Right to data portability

5.3       In addition to the applicable rights outlined above, you may exercise your right under VCDPA to opt out of the sale of personal information processed by emailing us at dpo@charlestaylor.com.

5.4       Charles Taylor does not process your data for targeted advertising purposes or carry out profiling on you or your behavior and/or habits. You will not be discriminated against for exercising any of your data rights.

6.       California residents

6.1       If you are a California resident from whom we collect personal information as a business under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), you may rely on the Global Privacy Notice and the additional information below.

6.2       For the purpose of this section for California residents, “Personal Information” means 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, or as otherwise defined by the CCPA. Personal Information does not include information that is publicly available, deidentified, or aggregated (as those terms are defined in the CCPA) or otherwise excluded from the scope of the CCPA.

6.3       Charles Taylor does not process your data for targeted advertising purposes or carry out profiling on your Personal information. You will not be discriminated against for exercising any of your data rights.

6.4       We do not use, disclose or sell sensitive Personal information for purposes which would require us to offer consumers the right to limit our collection and processing of this data under the CCPA.

6.5       We may disclose your Personal Information in limited circumstances, specifically for fraud prevention and identity verification purposes, as detailed further below. We do not engage in “cross-context behavioral advertising” (“CCBA”)” or share Personal information with third parties for such purposes.”

The following is a list of categories of Personal information (as defined by the CCPA) we have shared.

1. Identifiers (e.g., personal and business contact information, date of birth, home address, email address, phone number)  
2. Characteristics of Protected Classifications under California or Federal Law (e.g., gender, family status, age range, and military and veteran status) 
3. Sensory information (e.g., photographs, audio recordings (including call recordings for customer service purposes), and video recordings) 
4. Professional or Employment-Related Information (e.g. job title, department, name of organisation)

6.6         CCPA Definition of 'Selling' Personal Information

The CCPA defines "selling" Personal Information to include providing it to a third party in exchange for valuable services. We disclose identifiers and internet or other electronic network activity information to certain third parties in exchange for valuable services, such as our business partners who we may work with to improve our services, to provide analytics insights or other business benefits, which may constitute a "sale" under the CCPA.  

7.       Categories of Personal Information that we Collect and Disclose

7.1       The following is a list of categories of Personal Information (as defined by the CCPA) we have collected and disclosed for a business purpose:

• Identifiers (e.g., personal and business contact information, date of birth, home address, email address, phone number)
• Characteristics of Protected Classifications under California or Federal Law (e.g., gender, family status, age range, and military and veteran status)
• Sensory information (e.g., photographs, audio recordings (including call recordings for customer service purposes), and video recordings)
• Professional or Employment-Related Information (e.g., job title, department, name of organisation)
• Sensitive Personal Information (e.g., health information or biometric information for fraud and security prevention). We do not use, disclose or sell sensitive personal information for purposes which would require us to offer consumers the right to limit our collection and processing of this data under the CCPA.

8.       Sources of Collection of Personal Information

8.1       Charles Taylor obtains the categories of personal information referred to above from the following categories of sources:

• Directly from you. For example, from forms you complete or through the services we provide to you. The data collected will vary depending on the type of service we are providing,
• Third parties such as a person or agency you have directed to share information with us,
• Sources where we believe this is necessary to manage a claim you may have with us. For example, public registers, databases managed by credit references agencies, government agencies and other reputable organisations,
• Service providers that may be used to collect information on our behalf,
• Individuals linked to any claim you are making with us such as witnesses and persons representing you,
• We may collect information automatically using log files, cookies and other mechanisms including IP addresses, the date and time of visits, the referral URL and information about your browser, cookies and online identifiers,

8.2       We will only use your information in ways we are allowed to by law, which includes only collecting as much information as we need.

9.         Use of your Personal Information

9.1       During the past twelve (12) months, our practices with respect to the collection, use and disclosure of your personal information is reflected in the Global Charles Taylor Privacy Notice and Fair Processing Notice.

9.2       We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.

We do not use or disclose sensitive personal information for purposes which would require us to offer consumers the right to limit under the CCPA.

10.     Collection and Sale of your Personal Information to Other Parties

10.1     Under the CCPA “Sale” is the selling, sharing, or disclosing of consumers’ personal information in exchange for valuable consideration.

10.2     We only sell your Personal Information for fraud prevention and identity verification purposes, as detailed further below. We do not “share” Personal Information with third parties for “cross-context behavioral advertising” (“CCBA”).

10.3     The following is a list of categories of Personal Information (as defined by the CCPA) we have sold.

• Identifiers (e.g., personal and business contact information, date of birth, home address, email address, phone number)
• Characteristics of Protected Classifications under California or Federal Law (e.g., gender, family status, age range, and military and veteran status)
• Sensory information (e.g., photographs, audio recordings (including call recordings for customer service purposes), and video recordings)
• Professional or Employment-Related Information (e.g., job title, department, name of organisation)

11.     Retention

11.1     We use the following criteria to determine the period of time for which we retain each category of personal and sensitive information:

• The length of time we have an ongoing relationship with you (for example, for as long as you use our services)
• For as long as reasonably necessary for business purposes related to providing you with services (for example, for internal reporting and reconciliation purposes, or to provide you with feedback on information you might request)
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of our engagement for a certain period of time before we can delete them or where we have agreed to retain these records due to our client’s legal or other obligations); or
• Whether retention is necessary in light of our legal position (such as in regard to applicable statues of limitations, litigation or regulatory investigations)

12.     Your Privacy Rights

12.1      If you are a California resident, you have the following consumer rights, in line with the California Consumer Privacy Act of 2018 (CCPA).

• Right to access
• Right to portability
• Right for deletion
• Right to correction
• Right to limit the use of sensitive personal information

12.2       You have the right to request that Charles Taylor disclose certain information to you about our collection and use of your personal information over the past 12 months.

12.3       You have the right to request that Charles Taylor delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information as well as direct our service providers to delete your personal information, unless an exception applies.

Please note that you may only make a verifiable consumer request twice within a 12-month period.

12.4       You have the right to request that we correct inaccurate personal information about you. We will take into account the nature of the personal information and the purposes of the processing of the personal information in responding to your request. We will process your request if we receive a verifiable request and we will use commercially reasonable efforts to correct the inaccurate personal information as directed pursuant to the CCPA.

12.5       You have the right, at any time, to direct us to limit our use of your sensitive personal information only to that use which is necessary to perform the services or provide the goods reasonably expected or to fulfil the reason that we collected such information and/or other permissible business purposes. Please see the Global Charles Taylor Privacy Notice and Fair Processing Notice which detail the types of sensitive personal information we may collect.

12.6       We do not use or disclose your sensitive personal information for purposes other than to provide you with products and/or services. However, note that this information may be used, or disclosed to a service provider or contractor pursuant to a written agreement in order to provide such products and/or services. If you choose to limit such use, you can opt-in to such use again by contacting us via email. Note that this right does not apply to sensitive personal information that is collected or processed without the purpose of inferring characteristics about you.

12.7       We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within those forty-five (45) days.

If you wish to exercise any of your consumer rights, please submit a verifiable consumer request by contacting DPO@charlestaylor.com.

12.8       Only you, or a person registered with the California Secretary of State that you authorise (“authorised agent”) 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.

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

If you are acting as an authorised agent to make a request to know, delete, correct, or opt out on behalf of a California resident, you may submit a request by contacting dpo@charlestaylor.com.

Please note that we will require you to attach a written authorisation signed by the resident whose Personal Information will be subject to the request.

13.     Changes to this Privacy Notice

13.1     Charles Taylor reserves the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our services following the posting of changes constitutes your acceptance of such changes.

June 2023