Last Revised: January 1, 2023.

This Privacy Policy applies to personal information of California residents to the extent the information is subject to the California Consumer Privacy Act (“CCPA”). This privacy policy does not apply to personal information collected pursuant to (i) the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; or (ii) certain medical and health information covered by HIPAA. The CCPA applies to some, but not all, of our affiliated companies. Therefore, consumers whose information is processed by our affiliates that are not subject to the CCPA would not be entitled to the rights, or subject to the disclosures, provided below. Most information we collect and process is subject to the Gramm-Leach-Bliley Act or ‎otherwise ‎exempt from the CCPA. Personal information subject to the CCPA that we process is primarily ‎in the context of hiring, employment, business-to-business communications, and our website.

Personal Information We Collect, Use, Disclose, Share, or Sell

Categories of Personal Information We Collect, Categories of Sources of Personal Information, Business or Commercial Purposes for Which Personal Information Will Be Used, and Third Parties with Whom Personal Information is Sold, Shared, or Disclosed.

We collect 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”). Within the last twelve (12) months, we may have collected the following categories of personal information from the sources identified below for the business and commercial purposes indicated, and disclosed, shared, or sold (as indicated) such categories of personal information with the specified categories of third parties:

Category of Personal Information Examples of Personal Information Collected Categories of Sources of Personal Information Collected Business or Commercial Purpose(s) for Which Collected or Disclosed Categories of Third Parties to Which Personal Information is Disclosed
Identifiers Includes direct identifiers, such as Name, alias user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; SSN, driver’s license number, passport number, tax ID and other government identifiers; and other similar identifiers.
  • Directly from the individual or their intermediary.
  • From our affiliates and agents.
  • From third party service providers who perform business, professional, or
    other functions for us, such as recruitment platforms or web-analytics
  • To inform you of and provide services and products to you that you request
    from us.
  • To fulfill the reason for which the personal information was provided.
  • For human resources purposes.
  • To process, service, and enforce transactions with you or entities
    affiliated with you.
  • To present our website and contents to you.
  • To notify you about changes to our website, policies, products or
    services.
  • To support, change, improve, and develop our products and services.
  • For research, analysis, modeling, marketing, or advertising purposes.
  • Fraud detection and prevention.
  • To respond to law enforcement requests and as required by applicable law,
    court order, or governmental regulations.
  • To protect the rights, property, or safety of ourselves, our partners and
    others.
  • To compile statistics for analysis.
  • To help maintain the safety, security, and integrity of our systems, services,
    databases and other assets.
  • Insurance agencies and companies.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other
    functions for us.
  • Governments as required by law.
Personal Information Categories Listed in the California Customer Records
statue
(Cal. Civ. Code 1798.80(e))
Includes personal information, such as name, account name, user ID, contact
information, education and employment information, SSN and government identifiers,
account number, and financial or payment information), that individuals provide us
in order to purchase or obtain our products and services. For example, this may
include information collected when an individual registers for an account, purchases
or orders our products and services, or enters into an agreement with us related to
our products and services.
Characteristics of protected classifications under California or federal
law
Includes characteristics of protected classifications under applicable/federal and
state/federal and California laws, such as disability information and medical
conditions (e.g., which we may collect in order to make available appropriate
accommodations for events and other activities or TTY services).
Commercial Information Includes records of personal property, products or services purchased, obtained, or
considered, or other purchasing or use histories or tendencies. For example, this may
include demographic information that we receive from third parties in order to better
understand and reach our customers.
Biometric Information We do not collect Biometric Information.
  • Insurance agencies and companies.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other
    functions for us.
  • Governments as required by law.
Internet or other electronic network activity information Includes browsing history, clickstream data, search history, access logs and other usage
data and information regarding an individual’s interaction with our websites, mobile
apps and other Services, and our marketing emails and online ads.
Geolocation data Includes precise location information about a particular individual or device.
Sensory Data Includes audio, electronic, visual, thermal, olfactory, or similar information such as
photographs and images (e.g., that you provide us or post to your profile) and call
recordings (e.g., of customer support calls).
Professional or employment-related information Includes professional and employment-related information (such as current and former
employer(s) and position(s), business contact information and professional
memberships).
  • Insurance agencies and companies.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other
    functions for us.
  • Governments as required by law.
  • Third party recruiting partners and service providers.
  • Social networks with recruitment functionality such as Linked-In.
Non-public education information (as defined in the Family Educational Rights and
Privacy Act (20 U.S.C. 1232g, 34 C.F.R. Part 99))
Information about an individual’s educational history (such as the schools attended,
degrees you were awarded, and associated dates).
Inferences drawn from other personal information Includes inferences drawn from other personal information that we collect to create a
profile reflecting an individual’s preferences, characteristics, predispositions,
behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze
personal information in order to identify the offers and information that may be most
relevant to customers, so that we can better reach them with relevant offers and ads.
  • Insurance agencies and companies.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other
    functions for us.
  • Governments as required by law.
Sensitive Personal Information Includes a consumer’s social security, driver’s license, state identification card, or
passport number.
A consumer’s account log-in, financial account, debit card, or credit card number in
combination with any required security or access code, password, or credentials allowing
access to an account.
A consumer’s precise geolocation.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union
membership.The contents of a consumer’s mail, email, and text messages unless the business is the
intended recipient of the communication.
Also includes A consumer’s genetic data and the processing of biometric information for
the purpose of uniquely identifying a consumer.
Also includes Personal information collected and analyzed concerning a consumer’s
health.
Directly from individuals who work for or with us as company personnel, or through those
individuals’ intermediaries.
For human resources purposes.
  • Insurance agencies and companies.
  • Our affiliates and agents.
  • Third party service providers who perform business, professional, or other
    functions for us.
  • Governments as required by law.

We do not sell personal information. We do not share personal information for the purpose of cross-context behavioral advertising.

We do not sell or share the personal information of minors under 16 years of age. We do share cookies with third parties as described in our online privacy policy. To opt-out of the sharing of information with third parties in this context, please review our online privacy policy for instructions or adjust your browser settings accordingly.

We do not use or disclose sensitive personal information for purposes other than the following:

  • (1) To perform the services or provide the goods reasonably expected by an average ‎consumer who requests those goods or services.
  • (2) To prevent, detect, and investigate security incidents that compromise the availability, ‎authenticity, integrity, or confidentiality of stored or transmitted personal information,
  • (3) To resist malicious, deceptive, fraudulent, or illegal actions directed at the business ‎and to prosecute those responsible for those actions.‎
  • (4) To ensure the physical safety of natural persons.
  • (5) For short-term, transient use, including, but not limited to, nonpersonalized ‎advertising shown as part of a consumer’s current interaction with the business, provided ‎that the personal information is not disclosed to another third party and is not used to ‎build a profile about the consumer or otherwise alter the consumer’s experience outside ‎the current interaction with the business.
  • (6) To perform services on behalf of the business.
  • (7) To verify or maintain the quality or safety of a product, service, or device that is ‎owned, manufactured, manufactured for, or controlled by the business, and to improve, ‎upgrade, or enhance the service or device that is owned, manufactured by, manufactured ‎for, or controlled by the business.
  • (8) To collect or process sensitive personal information where such collection or ‎processing is not for the purpose of inferring characteristics about a consumer.

Your Privacy Rights

Right to Notice

You have the right to receive notice at or before the point of collection about our collection and retention practices. Please review our notice at collection here for more information.

Submitting Consumer Requests

For details about how to submit a consumer request, you can visit our website http://www.ltcglobal.com/privacy-compliance.html or call ‎(888) 413-0444‎ to make a consumer request. You may make up to two disclosure requests in any 12 month period.

Only you, or someone legally authorized 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.

Making a verifiable consumer request does not require you to create an account with us.

When you submit a verifiable consumer request, we will take steps to verify your request ‎by email or telephone call. In some cases, we may request additional information in order to verify ‎your request or where necessary to process your request. If we are unable to adequately verify a ‎request, we will notify the requestor. Authorized agents will be required to provide proof of their ‎authorization and we may also require that the relevant consumer directly verify their identity and ‎the authority of the authorized agent.‎

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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.

Right to Know and Access Your Information

You have the right to request that we disclose to you certain descriptions and categories of the personal information we collect, use, disclose, share, or sell about you. For example, you may request the following:

  • (1) The categories of personal information we have collected about you.
  • (2) The categories of sources from which the personal information is collected.
  • (3) The business or commercial purpose for collecting, selling, or sharing personal information.‎
  • (4) The categories of third parties to whom we disclose the personal information.
  • (5) The specific pieces of personal information we have collected about you.

You may make up to two disclosure requests in any 12 month period.

Right to Request Deletion

You have the right to request that we delete your personal information. You may make such a request by visiting our website http://www.ltcglobal.com/privacy-compliance.html or calling ‎(888) 413-0444‎. See above for additional details.

You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.

Right to Request Correction

You have the right to request that we correct your personal information. You have the right to request that we delete your personal information. You may make such a request by visiting our website http://www.ltcglobal.com/privacy-compliance.html or calling ‎(888) 413-0444‎. See above for additional details.

Metrics

Below are metrics regarding Access, Delete and Do Not Sell My Personal Information requests submitted pursuant to the CCPA that we have received, fulfilled (in whole or in part), and denied between January 1, 2023 and December 31, 2023:

Access Requests

  • Number of Requests Received: 0
  • Number of Requests Fulfilled: 0
  • Number of Requests Denied/Unverified: 0
  • Average Number of Days to Respond: N/A

Delete Requests

  • Number of Requests Received: 1
  • Number of Requests Fulfilled: 0
  • Number of Requests Denied/Unverified: 1
  • Average Number of Days to Respond: 1

Do Not Sell Requests

  • Number of Requests Received: 0
  • Number of Requests Fulfilled: 0
  • Number of Requests Denied/Unverified: 0
  • Average Number of Days to Respond: N/A

If you have questions about this notice, please contact us at:

Phone: (888) 413-0444

Website: https://www.ltcglobal.com/privacy-compliance.html

Email: [email protected]