Updated 12/31/2019

Your privacy is important to us. This California Consumer Privacy Act Disclosure explains how Complete Solutions Inc and its subsidiaries (“we” or “us”) collects, uses, discloses, and sells personal information relating to California residents that is subject to the California Consumer Privacy Act of 2018 (“CCPA”).

What is Personal Information?

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. The CCPA, however, does not apply to certain information, such as information subject to certain federal privacy laws, like the Gramm-Leach-Bliley Act and the Health Insurance Portability and Accountability Act (“HIPAA”). As a result, this disclosure does not apply to information that we collect about California residents who request or obtain our financial products and services for personal family or household purposes or for long-term care or individual health products.

Our Collection, Use, Disclosure, and Sale of Personal Information

We collect Personal Information relating to California residents in a variety of contexts. For example, we collect Personal Information relating to individuals who visit and interact with our websites, request or obtain our products or services, apply for employment with us or are our employees, vendors, contractors or similar personnel, or visit our locations or facilities. The specific Personal Information that we collect, use, disclose, and sell relating to a California resident will depend on our relationship or interaction with that individual.

Additionally, our system may not respond to Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

In the past 12 months, we have collected the following categories of Personal Information relating to California residents:

1. Identifiers, such as name and Social Security number;
2. Personal information, as defined in the California safeguards law, such as contact information and financial information;
3. Characteristics of protected classifications under California or federal law, such as sex and marital status;
4. Commercial information, such as transaction and account information;
5. Biometric information, such as fingerprints and voiceprints;
6. Internet or network activity information, such as browsing history and interactions with our website;
7. Geolocation data, such as device location;
8. Audio, electronic, visual, thermal, olfactory, and similar information, such as call and video recordings;
9. Professional or employment-related information, such as work history and prior employer;
10. Education information, such as school and data of graduation; and
11. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.

The purposes for which we use the Personal Information that we collect depends on our relationship or interaction with a specific California resident. We use Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment and vendor management purposes, and to accomplish our business purposes and objectives. For example, we use Personal Information to personalize, develop, and market our products and services; conduct research and data analysis; operate and manage IT and communications systems; facilitate communications; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

In the past 12 months, we have disclosed the following categories of Personal Information relating to California residents to affiliated and nonaffiliated third parties for our business purposes:

1. Identifiers, such as name;
2. Personal information, as defined in the California safeguards law, such as contact information and financial information;
3. Characteristics of protected classifications under California or federal law, such as sex and marital status;
4. Commercial information, such as transaction and account information;
5. Biometric information, such as fingerprints and voiceprints;
6. Internet or network activity information, such as browsing history and interactions with our website;
7. Geolocation data, such as device location;
8. Audio, electronic, visual, thermal, olfactory, and similar information, such as call and video recordings;
9. Professional or employment-related information, such as work history and prior employer;
10. Education information, such as school and data of graduation; and
11. Inferences drawn from any of the Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.

In the past 12 months, we have sold the following categories of Personal Information relating to California residents to affiliated and nonaffiliated third parties (for purposes of this Disclosure, “sold” means the disclosure of Personal Information for monetary or other valuable consideration):

1. Identifiers, such as name;
2. Personal information, as defined in the California safeguards law, such as contact information and financial information;
3. Characteristics of protected classifications under California or federal law, such as sex and marital status;
4. Commercial information, such as transaction and account information;
5. Internet or network activity information, such as browsing history and interactions with our website;
6. Geolocation data, such as device location;(7) Professional or employment-related information, such as work history and prior employer; and
7. Education information, such as school and data of graduation.

Requests Under the CCPA

If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

1. the categories and specific pieces of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
2. the business or commercial purpose for collecting Personal Information about you;
3. the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed Personal Information (if applicable); and
4. the categories of Personal Information about you that we sold to third parties and the categories of third parties to whom we sold Personal Information (if applicable).

If you are a California resident, you may also request that we delete Personal Information we collected from you.

Finally, if you are a California resident, you have the right to opt-out of the sale of your Personal Information.

In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. In other instances, we may decline to honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer. We may also decline to honor your request where the Personal Information that we maintain about you is not subject to the CCPA’s access and/or deletion right, such as, in the case of a deletion request, information that we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How to Make Requests

If you are a California resident, you may make a request for the disclosures described above, make a request to delete Personal Information we collected from you, or opt-out of the sale of your Personal Information, by contacting us at (866) 866-7951.

You may also opt-out of the sale of your Personal Information by clicking the “Do Not Sell My Personal Information” link located on each webpage where Personal Information is collected.

Changes to This California Consumer Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.