Notice of California Consumer Rights Under the California Consumer Privacy Act

As of January 1, 2020

Overview:

This California Consumer Privacy Act Notice (“Notice”) applies to Lewitt Hackman (sometimes known as “Lewitt, Hackman, Shapiro, Marshall & Harlan,” “the firm,”, “we,”, “us,” or “our,”) and is effective as of the date noted above.

Lewitt Hackman cares about your privacy and does not sell your information to third parties. We do collect information however, and by agreeing to this Notice, you understand and consent to our collection of your personal information as described herein. Most of the personal information collected is provided by you personally, as clients or as visitors to our social media or web properties.

1. Business Purposes for Data Collection: Pursuant to the CCPA, we are required to inform you of the Business Purpose(s) for each category of Personal Information we collect at or before the time we collect such information from you. For purposes of the CCPA and this Privacy Policy: i) “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, ii) “Business Purpose” means the use of Personal Information for Lewitt Hackman’s operational or other specified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or processed or for another operational purpose that is compatible with the context in which the Personal Information was collected and iii)  “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, provided that the contract prohibits the entity receiving the information from retaining, using, or disclosing the personal information for any purpose other than for the specific purpose of performing the services specified in the contract for the business, or as otherwise permitted by law, including retaining, using, or disclosing the personal information for a commercial purpose other than providing the services specified in the contract with the business.

The following are the categories of Personal Information that we have collected from our users over the last 12 months (and examples of the types of information those include), the categories of sources from which that information was collected, the business or commercial purpose(s) for which the information was collected, the categories of third parties with whom we disclose the information for a business purpose, and the categories of third parties to whom this type of Personal Information is sold:

Category of Personal Information Collected Categories of Sources from Which the Information was Collected Business or Commercial Purpose(s) for Which Information is Collected Categories of 3rd Parties to Whom This Type of Personal Information is Disclosed for a Business Purpose
Identifiers We may collect this type of information from:
You, or
Cookies and Tracking Technologies, or
Third-party Service providers, or
Third-party social media companies, or
Third-party business partners.
These may allow you to participate in features we offer or provide related customer services, or
Recognize you across the Lewitt Hackman Platforms and across devices, or
Process a purchase or other transaction, or
Provide you with information, products, or services that you have requested or that we think may interest you, or
Investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, or
To comply with a legal obligation, such as respond to subpoenas or other legal processes, or
Process your registration, including verifying your information is active and valid, or
Contact you with regard to your use of our Platforms or any Lewitt Hackman service and, in our discretion, changes to the Lewitt Hackman platform policies.
We may disclose this type of information to:
Service providers, such as those who deliver our communications, or
Third-party advertising and analytics companies, or
Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).
Any categories of Personal Information described in subdivision (e) of Section 1798.80:
“Personal information” means any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
We may collect this type of information from:
You.
Allow you to participate in features we offer or to provide related customer services, or
Recognize you across the Lewitt Hackman platforms and across devices, or
Tailor content recommendations and offers we display to you, or
Process a purchase or other transaction, or
Provide you with information, products, or services that you have requested or that we think may interest you, or
Investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, or
Process your registration, including verifying your information is active and valid, or
Contact you with regard to your use of the Lewitt Hackman platforms or any Lewitt Hackman service and, in our discretion, changes to the Lewitt Hackman platform policies.
We may disclose this type of information to:
Service providers, such as those who deliver our communications, or
Third-party advertising and analytics companies, or
Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).
Commercial Information We may collect this type of information from:
You, or
Third-party Service providers, or
Third-party social media companies, or
Third-party business partners.
Allow you to participate in features we offer or to provide related customer services, or
Investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, or
Process a purchase or other transaction, or
Improve the Lewitt Hackman platforms or our services and for internal business purposes.
We may disclose this type of information to:
Service providers who provide services on our behalf (including as needed to complete your transactions, to assist with our information technology and security programs, to assist with loss and fraud prevention, and to provide professional services to Lewitt Hackman), or
Third parties with whom we have joint marketing and similar arrangements, or
Other third parties (including government agencies) as required by law.
Internet or Other Electronic Network Activity Information We may collect this type of information from:
Cookies and Tracking Technologies, or
Third Party Service providers.
Recognize you across the Lewitt Hackman Platforms and across devices, or
Tailor content recommendations and offers we display to you, or
Process a purchase or other transaction, or
Investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, or
Improve the Lewitt Hackman platforms or our services and for internal business purposes.
We may disclose this type of information to:
Service providers who assist with our information technology and security programs, who assist with loss and fraud prevention, and who provide professional services to Lewitt Hackman, or
Other third parties (including government agencies) as required by law.
Geolocation Data We may collect this type of information from:
Cookies and Tracking Technologies, or
Third Party Service providers.
This may allow you to participate in features we offer or to provide related customer services, or
Tailor content recommendations and offers we display to you, or
Investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies, or
Improve the Lewitt Hackman platforms or our services and for internal business purposes.
We may disclose this type of information to:
Service providers who assist with our information, technology and security programs and who provide professional services to Lewitt Hackman, or
Other third parties (including government agencies) as required by law.
Inferences drawn from any of the information identified above to create a profile about You We may collect this type of information from:
You, or
Cookies and Tracking Technologies, or
Third-party Service providers, or
Third-party social media companies, or
Third-party business partners, or
Third-party data resellers.
Tailor content recommendations and offers we display to you, or
Improve the Lewitt Hackman platforms or our services and for internal business purposes.
We may disclose this type of information to:
Service providers, such as third party advertising and analytics companies, or
Other third parties (including government agencies) as required by law.

2. Personal Information Sold to Third Parties: Pursuant to the CCPA we are required to provide certain disclosures and inform you of your rights if we sell your Personal Information to third parties. We do not currently, and do not intend to sell in the future, your Personal Information to third parties.

3. Right to Know: If you are a California resident and have used our services, you, or your Authorized Agent as described in Section 7 below, can request that we disclose to you the categories of Personal Information we collect from you, the categories of sources from which the Personal Information is collected, the business or commercial purpose of collecting and/or sharing your Personal Information, the categories of third parties with whom we shared your Personal Information and the specific pieces of Personal Information we have collected about you for the last 12 months. You have two options to obtain the above information: 1) you can fill out our interactive form HERE or you may 2) submit your request to: info@lewitthackman.com. Please note that for certain Personal Information, we may require you to take additional steps to confirm your identity, which may include a requirement for you and/or your Authorized Agent to get your request notarized.

4. Right to Deletion Request: Pursuant to the CCPA, if you are a California resident you can request deletion of the Personal Information we have collected from you. However, we are not required to comply with your request to delete your Personal Information if it is necessary for us or our service provider to maintain the Personal Information to:

a. Complete the transaction for which the Personal Information was collected; provide a good or service you requested; or if it is reasonably anticipated within the context of our ongoing business relationship with you that maintaining this information is needed, or if otherwise required to perform a contract between the us and you.
b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
c. Debugging purposes, to identify and repair errors that impair existing intended functionality.
d. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
e. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
f. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
g. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
h. Comply with a legal obligation.
i. Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

You have two options to request removal of content or information: 1) you can fill out our interactive form HERE or you may 2) submit your request to: info@lewitthackman.com.com. Please note that for certain Personal Information, we may require you to take additional steps to confirm your identity, which may include a requirement for you and/or your Authorized Agent to get your request notarized.

When processing a request to delete, we may erase some information and we may de-identify some information (when we de-identify information, we implement technical safeguards and business processes that prohibit re-identification, business processes to prevent inadvertent release of de-identified information, and will make no attempt to re-identify the information).

5. Right Not to be Discriminated Against: Under the CCPA, California consumers have the right not to receive discriminatory treatment from us for exercising any of your rights under the CCPA. We will not discriminate against you for exercising your rights under the CCPA. If you feel you are being discriminated against by us for exercising your CCPA rights, please email: info@lewitthackman.com.

6. Authorized Agent: If you wish to submit a request through a natural person or a business entity registered with the Secretary of State that you have authorized to act on your behalf (“Authorized Agent”), we will need:

a. Written evidence from you that the Authorized Agent has permission to act on your behalf; and

b. Verification of the Authorized Agent’s identity.

7. Response Timing: When you request access to the Personal Information we have collected or deletion of your Personal Information, we will typically provide the requested information or perform the deletion within 45 days, and we will notify you within that time period if we need additional time to process your request.

8. Children/Minors: Under the CCPA, there are special rules relating to the collection and use of Personal Information of minors. As such, we have certain protections in place, described below.

a. Overview. We are respectful of the privacy rights of all of our users, and sensitive to the particular privacy concerns of children under the age of 13 (“Children” or “Child”). We will not require a Child to disclose more information than is reasonably necessary to access, purchase, browse and obtain info from Lewitt Hackman or use the interactive features of our services. If the user is a Child, the parent or guardian that signed them up for the services may also request access to review, update, or direct us to delete information on the Child in the same manner as a user with full access to the account by contacting us at: info@lewitthackman.com and note “Parental Rights Request” in the subject line of the email. You may also cancel the account to prevent any further collection or use of the Child’s information.

b. Registration Process for Children. All users may register through our website. For Children under 16, a parent or guardian must register their Child for our services on our website and complete our parental verification to show that you reviewed our notice of privacy practices, and confirm that you read, understand and agree to our terms of use as well as our data practices as set out in our Privacy Policy. This may be accomplished by either: 1) providing a credit card for validation of transactions made by the Child, or by 2) providing written consent signed by the parent under penalty of perjury by postal mail, facsimile or electronic scan.

c. Collection and Use of Personal Information. In signing up your Child for the service, you agree to the collection and use of your Child’s information as described in this CCPA Section of the Privacy Policy, but you may direct us not to disclose your Child’s Personal Information to third parties, except for disclosures as part of our services or as necessary to comply with Laws, governmental investigations or subpoenas. Lewitt Hackman will not share Personal Information of Children with any third parties other than as described in this Privacy Policy as necessary in providing our services, and Lewitt Hackman will not share Personal Information of Children with third parties for those third party’s marketing purposes.

d. Exercising Parental Rights. To exercise your parental rights, including to access or request deletion of Personal Information of your Child that we collect and maintain through the services, contact us at: info@lewitthackman.com and note “Parental Rights Request” in the subject line of the email or call the toll-free number below. In the body of the email, please include your Child’s Lewitt Hackman account user name, plus your contact information for verification purposes, and whether you are requesting access to your Child’s information, or if you are requesting deletion of your Child’s data. Note that if you request deletion, your Child’s user account will be terminated.

9. California Do Not Track Disclosure: Some browsers have a do not track feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser do not track signals, but we do provide you the option to opt out of interest-based advertising (“IBA”). To learn more about IBA or to opt-out of this type of advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.

10. Contact Information. If you have any questions about this Privacy Policy, please contact us at: info@lewitthackman.com or by mail at:

Lewitt Hackman
16633 Ventura Boulevard, 11th Floor
Encino, California 91436

For support by phone, call us at: 818-990-2120.

CCPA Privacy Policy Date: as of January 1, 2020

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