CPA.com: California Privacy Rights Statement

Last Updated: July 12, 2024

This California Privacy Rights Statement supplements the CPA.com website Privacy Policy (“CPA.com Privacy Policy”) and applies solely to personal information collected online and offline about California consumers, such as our website visitors, personnel of our business customers, business partners and job applicants. This California Consumer Privacy Statement does not apply to personal information collected about CPA.com personnel.

This California Privacy Rights Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CPRA”).

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Privacy Rights Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Civ. Code § 1798.80: signature, state identification card number, insurance policy number, bank account number, credit card number, debit card number, or other financial information, education information and medical information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this California Privacy Rights Statement) your personal information for the purposes described in the CPA.com Privacy Policy and for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing advertising and marketing services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity;
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
• Debugging to identify and repair errors;
• Undertaking internal research for technological development and demonstration;
• Managing career opportunities with us; and
• Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.

We do not use or disclose (and have not used or disclosed during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) “sensitive personal information” (as defined under the CPRA) for any purpose other than those permitted under the CPRA.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the CPA.com Privacy Policy and this California Privacy Rights Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements, and for purposes of satisfying any legal, accounting or reporting requirements.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this California Privacy Rights Statement, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us
• Your devices, such as when you use our Services
• Our affiliates and subsidiaries
• Service providers, contractors and other vendors who provide services on our behalf
• Our joint marketing and business partners
• Online advertising services
• Data analytics providers
• Internet service providers (“ISPs”)
• Operating systems and platforms
• Social networks
• Publicly available data sources
• Recruiting and talent agencies
• Other individuals, such as referrals and job references
• Data brokers, such as public databases, credit bureaus, credit reporting service providers and background check services

Sale or Sharing of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross- context behavioral advertising purposes. This kind of sharing may be considered a “sale” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month Privacy Rights Statement) the following categories of personal information about you to or with online advertising services and AICPA:

• Identifiers
• Commercial Information
• Online Activity
• Inferences

You have the right to opt-out of this disclosure of your information, as detailed below. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this California Privacy Rights Statement, we may have disclosed the following categories of personal information about you for the business purposes listed above to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Privacy Rights Statement, we may have disclosed personal

information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

• Access: You have the right to know what personal information we have collected about you, including the categories of personal information collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
• Shine the Light Request: You also may have the right to request that we provide you with
  1. a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and
  2. the identity of those third

How to Submit a Request. To submit an access, correction, deletion or Shine the Light request, please contact us at inquire@hq.cpa.com,. If you prefer to talk to someone on the phone, or you have a disability or situation that makes it difficult to submit your requests as described above, you may call 855.855.5272. For any written request please include “CPRA” in your notice. You can opt-out of the sale or sharing of your personal information by contacting us or using the Global Privacy Control (“GPC”) signal at https://globalprivacycontrol.org/. Like with other types of browser-specific controls, if you use the GPC, we will process it for the browser from which you submit the request, but the opt-out request will not apply outside of the browser to your device, account, or offline sales or sharing. After using the GPC, if you clear your cookies in your browser, you will need to use the GPC again for us to process your opt-out for that browser. To submit a request as an authorized agent on behalf of a consumer, please contact us at inquire@hq.cpa.com or call 855.855.5272. For questions or concerns about our privacy policies and practices, please contact us as described in the “Contact Us” section of the CPA.com Privacy Policy.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an CPA.com account with us, we may verify your identity by requiring you to sign in to your account. If you do not have a CPA.com account with us and you request access to, correction of or deletion of your personal information, we may

require you to verify your email address or phone number in our records and/or provide any of the following information:

• Contact information (such as name, email, phone number, and address); and
• An indication of your prior contact with com (such as status as your prior contact with customer service, prior transaction with CPA.com, or other contact).

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.