California Privacy Policy
Your privacy is important to us at WittKieffer and its affiliates and subsidiaries (“WittKieffer,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act (“CRPA”) and implementing regulations.
This California Privacy Policy (“Policy”) describes how we collect, use, share, disclose, retain, and secure the personal information we gather about you through our website, https://www.wittkieffer.com/ (the “Site”), and when you interact with us as a customer or otherwise (collectively, the “Services”) when you use our website. We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.
What Information Do We Collect?
The below examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.
In the previous 12 months, we have collected the following categories of personal information:
| Category[1] | CCPA Representative Examples | Collected | Retention Period |
| A. Identifiers | 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. | Yes | No longer than necessary for the purposes for which the personal information is processed. |
| B. Personal Information | 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.
Some Personal Information included in this category may overlap with other categories. |
Yes | No longer than necessary for the purposes for which the personal information is processed. |
| C. Protected Classification Characteristics Under California or Federal Law | 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). | Yes | No longer than necessary for the purposes for which the personal information is processed. |
| D. Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No | N/A |
| E. Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No | N/A |
| F. Internet or Other Similar Network Activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes | No longer than necessary for the purposes for which the personal information is processed. |
| G. Geolocation Data | Physical location or movements. | No | N/A |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes | No longer than necessary for the purposes for which the personal information is processed. |
| I. Professional or Employment-Related Information | Current or past job history or performance evaluations. | Yes | No longer than necessary for the purposes for which the personal information is processed. |
| J. Non-Public Education Information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No | N/A |
| K. Inferences Drawn of the Consumer | Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No | N/A |
| L. Sensitive Personal Information | Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or genetic data.
Biometric information processed for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Some Sensitive Personal Information included in this category may overlap with other categories. Purposes for collection: We have a legitimate interest to provide you with our services. Is the sensitive personal information sold or shared? We may share your personal information with: · Our group companies (for example, to hire a candidate in another country or apply for a vacancy in another country) where you have requested us to do so and/or it is in our legitimate interests to do so for internal administrative purposes. · Contracted third parties or categories of third parties conducting background verification services. · Our clients in the course of conducting our recruiting assignments. · Suppliers, service providers (for example Microsoft) and subcontractors who provide our systems and may access personal data stored within our solution(s) strictly to provide support and maintenance purposes. · Companies that assist in our marketing, advertising and promotional activities · Analytics and search engine providers that assist us in the improvement and optimization of our website. |
Yes | No longer than necessary for the purposes for which the personal information is processed. |
[1] Categories of Personal Information are as defined in Cal. Civ. Code. § 1798.140(v) (effective Jan. 1, 2023).
Sources From Which Personal Information Is Collected
We collect your personal information directly from you, from your interaction with the Site, from publicly available sources, such as those recommending you for a vacancy or professional social networking websites, for example, LinkedIn. We also collect personal information from third parties which collect the personal information directly from you like Zoominfo.
Business or Commercial Purposes for Which Personal Information Is Collected
Your personal information is used for the following purposes:
- To present our Services and its contents in a suitable and effective manner for you and your device;
- To contact you to provide you with information or services that you request from us;
- To advertise opportunities, services, or special events that we think may be of interest to you;
- To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
- To carry out our obligations and enforce our rights arising from any contracts; and
- To notify you about any additions, upgrades, or changes in our services.
Third Parties with Whom Personal Information Is Disclosed, Shared, or Sold
In the preceding 12 months, we have disclosed the following personal information about consumers for business purposes:
- We share personal information in categories A (identifiers), B (personal), C (protected class), F (internet), H (sensory data), and I (professional or employment-related), with third parties and Contractors who are limited (by law and by contract) in their ability to use your personal information. We ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
- We allow certain companies to use personal information in categories F (internet), G (geolocation) and K (inferences) to enhance online experiences and customize advertising.
- We share personal information in category A (identifiers) with vendors and business partners so that they can provide services to you.
In the preceding 12 months, we have shared for cross-contextual advertising the following the personal information about consumers:
- We have shared personal information in categories A (identifiers), and B (personal), to third parties so that they can market products, information, campaigns, or services to you.
In the preceding 12 months, we have not sold any personal information beyond the analytic tools that you have consented to via the cookie policy on our web site; nor have we shared personal information about consumers to our clients without the consumers’ direct consent.
We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. You must be 18 or over to receive Services from us. Our website and Services are not directed at children, and we do not knowingly collect any personal information from children. If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible. Please contact us at [email protected] if you are aware that we may have inadvertently collected personal information from a child.
Individual Rights
Right to Know About Personal Information Collected, Disclosed, Shared, or Sold
You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties. There are two types of Rights to Know requests that you can make:
- Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
- Categories of personal information collected, sold, or shared;
- Categories of sources from which personal information is collected;
- Categories of third parties to whom the information is sold, shared or disclosed;
- Business or commercial purpose for collecting, sharing, or selling personal information;
- Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
- Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
- Specific pieces of personal information collected about you.
This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.
Right of Deletion
You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.
Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt-out of the sale or sharing of your personal information by a business, subject to certain laws and regulations.
We recognize the Global Privacy Control. Your browser must be able to support the Global Privacy Control for us to recognize your opt-out preference signal.
You may also visit our cookie settings found at the bottom of our web site to enable or disable specific types of cookies.
Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.
For more information, please visit our California Residents: Do Not Sell or Share My Personal Information Page here.
Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
Right of Correction
If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request. Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.
Right to Limit Use and Disclosure of Sensitive Personal Information
If we collect Sensitive Personal Information (as defined in Cal. Civ. Code § 1798.140(ae) (effective Jan. 1, 2023)) about you with the purpose of inferring characteristics about you, then you have the right to request that we limit the use of such information to the use which is necessary to perform the services we offer or for other permitted purposes under Cal. Civ. Code § 1798.121 (effective Jan. 1, 2023) upon receipt of verifiable request.
For more information, please visit our Notice to California Residents page, here. 
Submitting Requests
You can submit your request by emailing us at [email protected], or by toll-free phone at 866.775.8675 or by submitting your request via the Notice to California Residents page here
Verifying Requests
To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the consumer to whom the request relates prior to processing the request. To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.
Authorized Agents
You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in WittKieffer denying your request.
Contact Us
If you have any questions about this Privacy Policy, please contact us by email at, [email protected], or via phone at 866.775.8675.