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Last Revised on 1/01/2020
This Privacy Policy for California Residents (“California Privacy Policy”) supplements the information contained in Neighborly’s primary privacy policy. Dwyer Franchising LLC d/b/a Neighborly (“we,” “us,” or “our”) has adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.
This California Privacy Policy is parallel in scope to our privacy policy.
Table of Contents
Definitions Specific to this Policy
The Personal Information We Collect and Disclose
Definitions Specific to this Policy
The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to Neighborly’s privacy policy, including the following terms:
“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. Personal Information does not include publicly available information obtained from government records; de-identified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared.
As this chart shows, we disclose certain Personal Information to third parties for a business purpose. We also sell certain Personal Information to third parties. We do not sell the personal information of minors under 16 years old without affirmative authorization. This information covers the past 12 months.
|
Categories of Personal Information |
Examples: |
Types of Sources from which this Category of Personal Information Is Collected |
Business Purpose(s) for Collection |
Types of Third Parties with Whom this Category of Personal Information Is Sold and/or Disclosed |
|---|---|---|---|---|
|
Unique identifiers |
Name, signature, address, telephone email, account name, SSN, DL number, passport number, online identifier, or IP address. |
Website lead forms and point-of-sale (POS) systems. |
To provide the requested information, products, or services. Business intelligence and analysis. Customer relationship management (CRM) and marketing communications. Feedback collection. |
Digital advertising, social media partners, and data append. CRM. Call centers. |
|
Government ID number |
Social security number, passport number, driver’s license, or state identification card number. |
Not collected. |
N/A |
N/A |
|
Physical description |
Physical characteristics or description. |
Not collected. |
N/A |
N/A |
|
Financial information |
Bank account number, credit card number, debit card number, or any other financial information. |
Not collected. |
N/A |
Neighborly does not supply financial information to call centers, but its franchisees may provide it via granted access rights to their POS |
|
Health/medical information |
Medical information, or health insurance information. |
Not collected. |
N/A |
N/A |
|
Insurance information |
Insurance policy number, health insurance information. |
Point-of-sale system. |
Business intelligence and analysis. |
N/A |
|
Protected class data |
Characteristics of protected classifications under California or federal law, including race, ancestry, national origin, age (40 years or older), marital status, sex, sexual orientation, medical condition, disability, genetics, and veteran or military status. |
Third-party party data append partner. |
Business intelligence and analysis. |
N/A |
|
Purchase history |
Commercial information, including records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Point-of-sale system. |
Business intelligence and analysis. |
CRM. Neighborly doesn't supply financial information to call centers, but its franchisees may provide it via granted access rights to their POS |
|
Biometric data |
Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, |
Not collected. |
N/A |
N/A |
|
Internet activity |
Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. |
Website analytics and data solutions. |
Business intelligence and analysis. |
Digital advertising partners. |
|
Geolocation data |
Geolocation data. |
Website. Point-of-sale system. |
To provide relevant location-based service options. Business intelligence and analysis. |
Neighborly doesn't supply financial information to call centers, but its franchisees may provide it via granted access rights to their POS. |
|
Audio, visual, olfactory information |
Audio, electronic, visual, thermal, olfactory, or similar information. |
Not collected. |
N/A |
N/A |
|
Employment information |
Professional or employment-related information |
Not collected. |
N/A |
N/A |
|
Education information |
Personally identifiable education information that isn't publicly available (e.g. grades, financial aid). |
Not collected. |
N/A |
N/A |
|
Inferences |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Not collected. |
N/A |
N/A |
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following the submission of your request if this is the case.
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom we have shared that Personal Information; and (4) the business purpose for collecting that Personal Information, submit information request here or call 1-800-851-2230. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
- If you would like to request the specific pieces of Personal Information we collected about you, submit webform request here or call 1-800-851-2230. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request
- If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose, request for information here or call 1-800-851-2230. The link will take you to an interactive web form that you can complete and submit to make a request for information that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Verification Process
Upon receipt of the personal information request from the consumer, Neighborly will attempt to identify the consumer in one of three ways before initiating the request to know, request to opt-out, or request to delete procedures. Consumers authenticated under an existing password-protected account are automatically verified. For unauthenticated consumers that submit a request to know, two data points are used to identify the consumer before the process is initiated. For unauthenticated consumers that submit a request to delete, three data points are used to identify the consumer before the process is initiated.
Non-Discrimination
We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.
Deletion of Your Personal Information
You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, you can delete personal information here or call 1-800-851-2230. The link will take you to an interactive web form that you can complete and submit to make a request for deletion that we will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Authorized Agents
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
- Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.
Personal Information of Minors—Opting In
We do not sell the Personal Information of minors who are at least 13 years old and less than 16 years old unless those individuals have opted into the sale of their Personal Information. To opt-in, such a minor must first clearly request to opt-in via the link below, after which the minor will be required to separately confirm that election. As part of that confirmation process, the minor will be informed that he or she has the right to opt-out at a later date and what the process is for doing so.
If you are 13, 14, or 15 years old and would like to opt into the sale of your Personal Information, opt in here.
We do not sell the Personal Information of minors who are under 13 years old unless a parent or guardian of that minor affirmatively authorizes the sale of that Personal Information. We verify that the individual making such authorization is the minor’s parent or guardian by providing a consent form to be signed by the parent or guardian under penalty of perjury and returned to the business by postal mail, facsimile, or electronic scan.
As part of that verification process, the parent or guardian will be informed that he or she may opt out on behalf of the minor at a later date and what the process is for doing so.
If you are the parent or guardian of a minor under 13 years old and would like to opt in to the sale of the minor’s Personal Information, click to opt in here.
Personal Information Metrics
|
Type of Request |
Number received |
Number complied with (in whole or in part) |
Number denied |
Median number of days to provide a substantive response |
|---|---|---|---|---|
|
Request to Know |
0 |
0 |
0 |
0 |
|
Request to Delete |
0 |
0 |
0 |
0 |
|
Request to Opt-Out |
0 |
0 |
0 |
0 |
The above information is for the prior calendar year.
Right to Opt-Out
You have the right to request that we do not sell Personal Information that we have collected. If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
- If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, start your deletion request here or call 1-800-851-2230. The link will take you to an interactive web form that you can complete and submit to make a request for deletion. If you use the telephone number, you will be guided through a process that will allow you to submit a request.
- You may also submit a request to opt-out by sending an email with the required information to the following email address [email protected].
- If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.
You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale of your Personal Information, opt in here or call 1-800-851-2230. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.
Additional Information
If you would like additional information regarding our California Privacy Policy, please call 1-800-851-2230 or email us at [email protected].
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”
You may view our main privacy policy or contact us at [email protected] or 1-800-851-2230 with any questions.
Changes to Our California Privacy Policy
Neighborly reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.
Link to Go Back to Start of California Privacy Policy:
California Consumer Privacy Policy
