CCPA privacy notice

Effective Date: January 1, 2023

Last Reviewed on: January 25, 2024

This CCPA/CPRA Privacy Notice for California Residents (this “Privacy Notice”) supplements the information contained in Sectigo’s Privacy Policy (https://sectigo.com/privacy-po...) and applies solely to all visitors, users, and others, as well as Sectigo employees and job applicants who reside in the State of California (“consumers”, “employee”, “job applicant”, “contractor”, or “you”).

We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), (collectively, “CCPA/CPRA”) and any terms defined in the CCPA/CPRA have the same meaning when used in this Privacy Notice. All other terms, unless otherwise specified in this Privacy Notice, shall have the definitions assigned to them in the Privacy Policy.

As of January 1, 2023, the CPRA expands the CCPA so that it provides the same data privacy rights that it provides to consumers to employees and job applicants, or other similarly situated individuals.
Where noted in this Privacy Notice, the CCPA/CPRA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

Information we collect

We collect 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 employee, job applicant, consumer, household, or device (“personal information”). The CPRA adds a second category of personal information, referred to as sensitive personal information (“sensitive personal information”). Sensitive personal information is personal information that reveals: (i) a consumer’s social security, driver’s license, state identification card, or passport number; (ii) 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; (iii) a consumer’s precise geolocation; (iv) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (vi) a consumer’s genetic data; (vii) the processing of biometric information for the purpose of uniquely identifying a consumer; (viii) personal information collected and analyzed concerning a consumer’s health; or (iix) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. Neither Personal information nor Sensitive Personal Information includes:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers, employees, job applicants, and contractors within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you (e.g. from forms you complete; from products and services you purchase).
• Indirectly from you (e.g. from your employer; observing your actions on one of our websites or in your Account).

If you are a consumer, we do not collect any of your sensitive personal information.

If you are an employee, job applicant, or contractor we may collect the following sensitive personal information:

• Your social security, driver’s license, state identification card, or passport number;
• Your 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;
• The contents of your email, unless the business is the intended recipient of the communication
• Your racial or ethnic origin, religious or philosophical beliefs, or union membership;
• Personal information collected and analyzed concerning a consumer’s health.

Use of personal information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our websites, products, and services.
• To create, maintain, customize, and secure your Account.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our websites’ users is among the assets transferred.

If you are a consumer, we do not collect your sensitive personal information.

If you are an employee or job applicant, we may use or disclose your personal, and or, sensitive personal information we collect for one or more of the following purposes:

• Maintaining contact with prospective employee.
• Comply with all applicable laws and regulations.
• Recruit and evaluate job applicants and candidates for employment.
• Conduct background checks.
• Manage your employment relationship with us, including for:
  • onboarding processes;
  • timekeeping, payroll, and expense report administration;
  • employee benefits administration;
  • employee training and development requirements;
  • the creation, maintenance, and security of your online employee accounts;
  • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
  • workers' compensation claims management;
  • employee job performance, including goals and performance reviews, promotions, discipline, and termination;
  • other human resources purposes
• Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
• Monitor, investigate, and enforce compliance with and potential breaches of Sectigo policies and procedures and legal and regulatory requirements;
• Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons; and
• Exercise or defend the legal rights of Sectigo and its employees, affiliates, customers, contractors, and agents.

We will not collect additional categories of personal information, or sensitive personal information, or use the personal information, or sensitive personal information, we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing personal information or sensitive personal information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Our affiliates.

Our employees, contractors, and prospective employees (job applicants) that live in California have the same rights over their employment and job application data as consumers. We do not sell or share any employee or job applicant data with anyone other than third-party service providers necessary to complete requested services (e.g. payroll and benefits management, background check vendors).

Disclosures of personal information for a business purpose

In the preceding twelve (12) months, Sectigo has disclosed the following categories of consumer personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial Information.
• Category F: Internet or other similar network activity.

In the preceding twelve (12) months, Sectigo has disclosed the following categories of employee, job applicant, and/or contractor personal information for a business purpose:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category D: Commercial Information.
• Category E: Biometric Information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation Data.
• Category I: Professional or employment-related information.

In the preceding twelve (12) months, Sectigo has disclosed the following categories of employee, job applicant, and/or contractor sensitive personal information for a business purpose:

• Your social security, driver’s license, state identification card, or passport number;
• Your 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;
• The contents of your email, unless the business is the intended recipient of the communication
• Your racial or ethnic origin, religious or philosophical beliefs, or union membership;
• Personal information collected and analyzed concerning a consumer’s health.

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Our affiliates.

Sales of personal information

In the preceding twelve (12) months, Sectigo has not sold or shared personal information for purposes beyond those authorized by the CCPA/CPRA. Relatedly, we do not have actual knowledge that we sell or share personal information of California consumers under 16 years of age.

Your rights and choices

The CCPA/CPRA provides consumers, employees, and job applicants (California residents) with specific rights regarding their personal information, and, where applicable, sensitive personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Access to specific information and data portability rights

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. Once we receive and confirm your verifiable request (see Exercising Access, Data Portability, Deletion, and Correction Right) 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 business 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 data portability request).
• 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; an
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion request rights

You have the right to request that we delete any of your personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Exercising Access, Data Portability, Deletion, and Correction Right) we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify 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 et. 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.

Correction request rights

You have the right to request that we correct any of the personal information, or sensitive personal information, that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request (see Exercising Access, Data Portability, Deletion, and Correction Right), we will correct (and direct our service providers to correct) your personal information, or sensitive personal information, in our records, unless an exception applies.

We may deny your correction request if:

• Correcting the data would be impossible or would involve disproportionate effort; or
• If the request is to correct accurate data.

Exercising access, data portability, deletion, and correction rights

To exercise the access, data portability, deletion, correction rights described above, please submit a verifiable consumer request to us by either:

• Calling us at (888) 266-6361.
• Emailing us at [email protected]
• Visiting us at https://www.sectigo.com/support

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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The 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 representative.
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

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.

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

We will only 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 a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 45 or 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt. 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 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/no retaliation

We will not discriminate and/or retaliate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA/CPRA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Retention criteria

We will maintain certain consumer data for as long as is mandated by our industry requirements. As of the publication of this CCPA/CPRA Privacy Notice, we must maintain the information used to validate a certificate for at least seven (7) years after the termination of a subscriber agreement,

We retain employee personal information, and sensitive personal information, for the duration of the employment relationship with us and longer as may be required by applicable laws or necessary for our legitimate business purposes.

We retain job applicant personal information and sensitive personal information indefinitely.

Other California privacy rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Changes to this privacy notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Website and update the Privacy Notice effective date. Your continued use of our websites following the posting of changes constitutes your acceptance of such changes.

Contact information

If you have any questions or comments about this Privacy Notice, the ways in which Sectigo collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (888) 266-6361

Website: https://www.sectigo.com

Email: [email protected]

Postal Address:

Sectigo, Inc. c/o Sectigo Limited

Attn: Legal Department

8800 E. Raintree Drive, Suite 110

Scottsdale, AZ 85260

United States