California Privacy Policy/Notice of Collection
Notice of Collection of Personal Information and Privacy Policy Under the California Privacy Rights Act ("CPRA")
Effective Date: As of January 1, 2023
Updated: As of July 31, 2023
This Notice of Collection Of Personal Information and Privacy Policy ("CPRA Privacy Notice") applies to the collection of personal information from California residents as of and after January 1, 2023. This CPRA Privacy Notice supplements our “Privacy Notice” set forth above to provide California residents with additional information and rights required by the California Privacy Rights Act ("CPRA"). The CPRA Privacy Notice applies only to individuals residing in the State of California who are considered "consumers" under the CPRA and from whom we collect "personal information" as described in the CPRA.
This CPRA Privacy Notice describes the categories of personal information we collect, the business purposes for which we collect, use, and disclose your personal information, and your rights in personal information under the CPRA. We do not "share" your personal information with third party advertisers for cross-context behavioral advertising within the meaning of the CPRA. We do not sell your personal information.
Personal Information We Collect
For purposes of this CPRA Privacy Notice, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA including personal information that is within the scope of the Gramm-Leach-Bliley Act ("GLBA"). By using our website or services, or submitting your personal information to us, you consent to the collection, use and disclosure of your personal information as set forth in this CPRA Privacy Notice.
We collect the following categories of personal information. This table also sets out personal information we may have collected from you over the last twelve (12) months:
| Category | Examples |
|---|---|
| A. Identifiers | This information may include your name and contact details (including mailing addresses, telephone numbers, email addresses), IP address, browser or device identifier, and other identifying information you provide to us. |
| B. Any personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | This information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our business records. Some personal information in this category may overlap with other categories. |
| C. Commercial information | This category includes information concerning the services and products you requested to receive information on. |
| D. Internet or other similar network activity | This category comprises electronic information concerning your use of our website. This information may include information we automatically collect as you browse the website, including your IP address, device type/identifier, browser type/identifier, pages visited, and other similar electronic information. We may use services provided by outside organizations concerning your website activity to monitor and analyze your usage. We may collect information concerning your website usage through cookies and other technologies. |
| E. Geolocation data | We may determine your approximate physical location based on your IP address. |
| F. Inferences drawn from other personal information | We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our services and our website. |
We do not collect sensitive personal information for purposes of inferring characteristics.
We retain your information for as long as you maintain an ongoing relationship with us, as required by law, or as necessary to fulfill the purposes set out in this disclosure.
For California Job Applicants
If you are applying for a job opening, please see our Notice of Collection of Personal Information and Privacy Policy for California Job Applicants, which you can find here.
Categories of Sources of Personal Information
Rothschild & Co collects personal information from the following categories of sources:
- directly from you.
- service providers providing services on our behalf. We require our service providers and contractors who we provide your personal information to in order to provide services to maintain the privacy and security of your personal information.
- Third parties, including regulatory authorities and government agencies.
Use of Personal Information
Depending on the individual circumstances, we collect and use personal information for our legitimate business purposes as set forth above. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you additional notice.
Disclosure of your Personal Information
In some instances, we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, web hosting platforms, customer service providers, content providers, and shippers. Such outside organizations may be provided with access to your personal information to perform the functions for which they have been retained. Rothschild & Co requires its service providers, who provide services on our behalf to maintain the privacy and security of your personal information. Such service providers or contractors may be provided with access to your personal information to perform the functions for which they have been retained. By using our website or providing us with personal information, you consent to the disclosure of your personal information to our service providers.
We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.
- In the past twelve (12) months, we have not “shared” the categories of personal information collected in Categories A-F with third parties.
- In the past twelve (12) months, we have disclosed the categories of personal information collected in Categories A-F with the following outside organizations or entities who are not service providers or contractors providing services on our behalf: third parties to whom you authorize us to disclose your personal information in connection with benefits or services we provide to you; and governmental agencies and regulators when required by law.
Your CPRA Rights
Under the California Privacy Rights Act, you have the following rights in personal information held by us:
- You have the right to request that Rothschild & Co disclose the personal information that the Rothschild & Co collects, uses, and discloses about you. You may “request to know”: (i) the categories of personal information that Rothschild & Co has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom the Rothschild & Co discloses your personal information; and (v) the specific pieces of personal information that Rothschild & Co has collected about you. Your request may pertain to the personal information collected about you on or after January 1, 2022. If your request covers a time period beyond twelve (12) months from the date of your request, then Rothschild & Co may deny your request as to that time period where it would be impossible for the Rothschild & Co to provide you with the information or involve disproportionate effort. Rothschild & Co may deny your request to search for certain information under certain circumstances (e.g., where Rothschild & Co retains the information solely for legal and compliance purposes).
- You have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable format that allows you to transmit the information to another entity.
- You have the right to correct inaccurate personal information.
- You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose. Exceptions may include to (i) complete the transaction for which we collected the personal information, provide a good or benefit that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you; (ii) help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) make other internal and lawful uses of that information that are compatible with the context in which you provided it; and (vii) comply with our legal obligations.
- You have the right to know what information is shared with third parties, and to whom and to opt out of sharing for cross-context behavioral advertising. We do not sell or share your personal information.
- You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you products or services because you have exercised your rights.
You may submit verifiable requests concerning any of your rights by contacting us as provided for below. We will use reasonable methods for verifying that the person making a request to know, data portability, request to correct or a request to delete is the individual about whom we have collected personal information.
This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.
We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten (10) business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five (45) calendar days of the request. If we need additional time to respond to your request beyond the forty-five (45) calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five (45) calendar days to respond to your request.
Changes to Our Privacy Notice
We reserve the right to amend this CPRA Privacy Notice at our discretion and at any time. By accessing our website or communicating with us after we make any such changes to this CPRA Privacy Notice, you are deemed to have accepted such changes. Please check this CPRA Privacy Notice regularly, and before you submit additional personal information via the website.
Financial incentives to California Consumers
We do not offer you various financial incentives such as loyalty programs, discounts and special offers when you provide us with contact information and identifiers such as your name and email address.
California Shine the Light Law/Online Privacy Protection Act
California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.
Do we honor “Do Not Track” requests or Global Privacy Controls?
We do not presently recognize browser “Do Not Track” requests or Global Privacy Controls. As noted above, we do not sell your personal information to third parties or share your information for purposes of targeting you with ads based on your online activity at other websites.
Access by Persons with disabilities
Persons with disabilities who need assistance accessing this CPRA Privacy Notice may contact us as provided for below, and depending on your individual needs, Rothschild & Co will grant reasonable requests to furnish this policy in an alternative format.
Children
We do not knowingly collect personal information from children under the age of 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. We do not sell any personal information, including the personal information of minors under 16 years of age.
Contact Information
If you have any questions or comments about this CPRA Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Mail: 1251 Avenue of the Americas, New York, NY 10020
Email: data.protection@rothschildandco.com
Telephone: 1-212-403-3500