Last updated: July 12, 2022
This Privacy Policy for California Residents (“Policy”) supplements the LTL Talc Committee Privacy Policy www.LTLTalcCommittee.com. It applies only to users of the Site who reside in the State of California (“consumers” or “you”). We have adopted 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 Policy.
This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Please note that the LTL Talc Committee has not sold and does not sell your personal information, as those terms are defined in the CCPA.
Information We Collect
The LTL Talc Committee collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we collect the following categories of personal information from California consumers:
| Category | Collected | Purpose |
| A. Identifiers, such as such as name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | No | N/A |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, contact information, and financial information such as bank account number, credit card number, and debit card number. | No | N/A |
| C. Protected Classification characteristics under California or federal law, such as age, citizenship, gender, marital status, and veteran status. | No | N/A |
| D. Commercial information, such as records of personal property or transactions. | No | N/A |
| E. Biometric information. | No | N/A |
| F. Internet or other similar network activity. | Yes, such information is automatically collected from users of the Site.
Such information may also be contained in data provided by users of the Site. |
To improve and optimize the Site and our services. |
| G. Geolocation data, such as device location and IP location | Yes, such information is automatically collected from users of the Site. | To improve and optimize the Site and our services. |
| H. Audio, electronic, visual, thermal, olfactory, or similar information, such as images and audio, video or call recordings created in the course of our communications. | No | N/A |
| I. Professional or employment-related information, such as current or past job history. | No | N/A |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | No | N/A |
| K. Inferences drawn from other personal information. | No | N/A |
In addition, we may use any of the above information the following purposes:
- To help maintain the safety, security, and integrity of our Site, databases, and other technology assets.
- For testing, research, and analysis.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
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.
How We Collect Personal Information
We collect personal information through the Site. All of the categories of personal information listed above from the following categories of sources:
- Directly from you, for example, from forms you complete or information that you submit.
- Indirectly from you, for example, from observing your actions on the Site.
- Your computer or other device, automatically, when you interact with the Site.
How We May Share Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
We have not sold and do not sell personal information.
Your Rights and Choices
The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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 purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- 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.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Provide information or a service that you requested.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug our Site 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 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.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
- Calling us at +1.212.209.4800
- [email protected]
- LTLTalcCommittee.com
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete 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.
You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected].
We do our best to respond substantively to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 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 our receipt of your request. 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 information or services.
Changes to This Policy
We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. If you continue to use the Site after the changes are posted, you will be deemed to have accepted such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which the LTL Talc Committee collects and uses your information described here, your choices and rights regarding such use, or your wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1.212.209.4800
Website: www.LTLTalcCommittee.com
Email: [email protected]
Postal Address: LTL Talc Committee, c/o Brown Rudnick LLP, 7 Times Square, New York, NY 10036, Attn: Susan Sieger-Grimm
If you need to access this Policy in an alternative format due to having a disability, please contact us at [email protected] or +1.212.209.4800.