Effective Date and Last Revised: February 25,
2021
Your California Privacy Rights Notice ("Notice") supplements the
information contained in the Privacy Policy of International Risk Management
Institute, Inc., and its subsidiaries and affiliates (collectively,
"IRMI," "we," "us," or "our") and
applies in certain circumstances solely to all natural persons who are
California residents ("consumers" or "you").
1.
California Consumer Privacy Act Notice
The California Consumer Privacy Act of 2018, as amended (collectively, the
"CCPA"), defines "personal information" broadly as
information that identifies, relates to, describes, is reasonably capable of
being associated with, or could reasonably be linked, directly or indirectly,
with a particular individual or household. This California Consumer Privacy Act
Notice also uses that definition for personal information.
a. Categories and Sources of Personal Information We Collect
Please see "What
Information Do We Collect and How Do We Collect It?" and
"Cookies
and Other Technologies; Do Not Track" in our Privacy Policy to
understand the categories of personal information we collect from or about you
and the categories of sources from which we obtain personal information.
Please see "What
Information Do We Collect and How Do We Collect It?" and
"Cookies
and Other Technologies; Do Not Track" in our Privacy Policy to
understand the categories of personal information we have collected from or
about consumers in the preceding twelve (12) months and the categories of
sources from which we have obtained personal information in the preceding
twelve (12) months.
b. Our Collecting, Using, and Disclosing or Sharing Personal
Information
We disclose or share personal information from or about you with our service
providers, third parties, and/or other parties for business purposes, such as
operational purposes and other purposes related to providing you with the
products and services you seek from us. We provide more information about the
business purposes or commercial purposes for which we disclose or share
personal information in "How We Use the Information We
Collect" and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy. We may
disclose or share any of the categories of personal information listed in
"What Information Do We
Collect and How Do We Collect It?," "Cookies and Other
Technologies; Do Not Track," "How We Use the Information We
Collect," and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy for
business purposes or commercial purposes.
Please see "How We Use the Information We
Collect" and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy to
understand the business purposes or commercial purposes for which we have
collected personal information in the preceding twelve (12) months.
We have disclosed or shared personal information for business purposes in
the preceding twelve (12) months as described in "How We Use the Information We
Collect" and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy. Any of the
categories of personal information listed in "What Information Do We Collect and
How Do We Collect It?," "Cookies and Other
Technologies; Do Not Track," "How We Use the Information We
Collect," and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy may have
been disclosed or shared for business purposes in the preceding twelve (12)
months.
We may disclose or share personal information from or about you with the
categories of third parties as described in "How We Use the Information We
Collect" and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy. We may
disclose or share any of the categories of personal information listed in
"What Information Do We
Collect and How Do We Collect It?," "Cookies and Other
Technologies; Do Not Track," "How We Use the Information We
Collect," and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy.
Please see "How We Use the Information We
Collect" and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy to
understand the categories of third parties with whom we have disclosed or
shared personal information in the preceding twelve (12) months.
We disclose or share personal information with our service providers, third
parties, and/or other parties, including with certain sponsors and exhibitors
in connection with registration for a course,
conference, or webinar and to help us market or advertise to you. Please see
"How We Use the
Information We Collect," "Cookies and Other
Technologies; Do Not Track," and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy.
California law may characterize our disclosing or sharing of the following
categories of personal information as a sale of personal information (including
in the preceding twelve (12) months)
- with certain sponsors and exhibitors in connection with registration for
a course, conference, or webinar: identifiers such as full name, postal
address, email address, job title, and employer's name; and
- with online advertising service providers, third parties, and/or other
parties to help us market or advertise to you: identifiers such as email
address, online activity such as internet or other electronic network
activity information, including, but not limited to, browsing activity,
search queries, search terms, and information regarding your interaction with
websites, applications, or advertisements, and inferences about any of the
information above that may relate to your preferences or other matters.
Please see "Cookies and Other
Technologies; Do Not Track," "What Information Do We Collect and
How Do We Collect It?," "How We Use the Information We
Collect," and "With Whom Do We
Disclose or Share Your Information?" in our Privacy Policy to
understand the commercial purposes for which we may have sold personal
information under California law in the preceding twelve (12) months.
We do not knowingly collect or sell the personal information of consumers
under sixteen (16) years of age.
c. Your Rights and Choices
Your Rights To Know
You have the right to request that we disclose certain information to you
about our collection, use, disclosure, and sale of your personal information in
the preceding twelve (12) months. Once we receive and confirm your request to
know, we will disclose the following to you.
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about
you
- Our business purpose or commercial purpose for collecting or selling that
personal information
- The categories of third parties with whom we share that personal
information
- The specific pieces of personal information we collected about you (also
called a request to know data portability request)
- If we sold or disclosed or shared your personal information for a
business purpose, two separate lists disclosing
- sales, identifying the personal information categories that each
category of recipient purchased, including categories of third parties,
and disclosures or sharing for a business purpose, identifying the
personal information categories that each category of recipient obtained,
including categories of third parties
Your Deletion Rights
You have the right to request that we delete any of your personal
information that we collected from you and retained, in certain circumstances.
Once we receive and confirm your request to delete, we will delete from our
records and direct our service providers to delete from their records your
personal information, in certain circumstances.
Exercising Requests To Know and Requests To Delete
To exercise the request to know and request to delete rights described
above, please submit a verifiable consumer request to us via Contact Us or via toll-free telephone at
(800) 827–4242. Only you or a person registered with the California Secretary
of State that you authorize to act on your behalf may make a verifiable
consumer request related to your personal information.
A verifiable consumer request must
- provide sufficient information that allows us to reasonably verify you
are the person about whom we collected personal information or an authorized
agent and
- describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
You may only make a request to know twice within a twelve (12)-month
period.
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
that the personal information relates to you.
We will use personal information provided in a verifiable consumer request
to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to requests to know and requests to delete within
forty-five (45) calendar days. If we require more time (up to an additional
forty-five (45) calendar days), we will provide you with notice and an
explanation of the reason that we will take more than forty-five (45) calendar
days to respond to the request.
We will deliver our written response via postal mail or via email, at your
option.
The response we provide will also explain the reasons we cannot comply with
a verifiable consumer request (including regarding a request to delete, whether
we have complied with that request), if applicable.
Any disclosures we provide will only cover the twelve (12)-month period from
the date that we receive the request to know.
For request to know 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, including via email.
We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded.
Your Rights to Opt out and Opt in
You have the right, at any time, to request that we not sell your personal
information to third parties ("request to opt out"). Consumers who
request to opt in to personal information sales may request to opt out of
future sales at any time.
To exercise the request to opt out right described above, you (or your
authorized agent) may submit a request to opt out to us via Contact Us or as outlined on the following
page: [Do Not Sell My Personal
Information].
We will comply with a request to opt out as soon as feasibly possible and no
later than fifteen (15) business days from the date we receive the request.
Once you make a request to opt out, we will wait at least twelve (12) months
before asking you to reauthorize personal information sales. However, you may
change your mind and request to opt in to personal information sales at any
time via Contact Us.
We will use personal information provided in a request to opt out to review
and comply with the request.
Please also see https://www.privacyrights.info/ or https://optout.privacyrights.info with respect to service
providers, third parties, and/or other parties regarding online tracking and
targeting and that participate in the opt-out tool.
Nondiscrimination
You have the right not to receive discriminatory treatment by us for the
exercise of the privacy rights conferred by the CCPA. Unless permitted by the
CCPA, we will not
- deny you goods or services;
- charge you different prices or rates for goods or services, including
through granting discounts or other benefits or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or
services or a different level or quality of goods or services.
2.
Additional Rights under California Law
California Civil Code Section 1798.83 permits individuals who are California
residents to request from a business, with which the California residents have
an established business relationship, certain information about the categories
of personal information the business has shared with third parties for those
third parties' direct marketing purposes and the names and addresses of the
third parties with whom the business has shared such information during the
immediately preceding calendar year. You can make one request each year by
writing to us at the following postal address.
International Risk Management Institute, Inc.
ATTN: Customer Success Department
12222 Merit Dr., Ste. 1600
Dallas, TX 75251
You must include the following in your writing.
- The statement "Your California Privacy Rights"
- Your name, postal address, city, state, and zip code
You also may include your email address in your writing.
We will respond to you at your postal address or, at our option, your email
address if you provided your email address in your writing.
If you have questions about our Privacy Policies, Notices, or privacy
practices, please contact us using the contact information noted in
"How To Contact Us" in our
Privacy Policy.
4. Notice Update
We reserve the right to update or modify this Notice, including without
limitation, the California Consumer Privacy Act Notice, at any time and from
time to time. Please review this Notice periodically and especially before you
provide any information or data. This Notice was made effective on the date
indicated above.