California Consumer Privacy Notice

Last updated 16th March 2023

If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”).  This Privacy Notice for California Residents supplements the information in our Privacy Policy and Cookie Policy available on our website, and applies solely to California residents.

This Notice applies to categories of personal information we collect and process for the business purposes listed below. It does not apply to personal information we collect from our employees or job applicants.

Categories of personal information collected

For purposes of this Policy, “Personal Information” means information (whether stored electronically or in paper based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession).  The items below describe the categories of Personal Information we have collected in the past twelve months. 

• Identifiers:  Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Commercial Information:  Commercial or transactions information; records of products or services purchased, obtained, or enquired about, and financial and credit card information used to purchase our products or services.
• Internet Activity:  The Internet protocol (IP) address used to connect consumer’s computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about consumer’s visits to our websites, including the full Uniform Resource Locators (URL), page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Geolocation Data:  Location history or movement.

Categories of sources

• We collect Personal Information directly from consumers when they browse our websites, fill in our online registration forms or content download forms, or when they register by phone or enquire by phone about our products and services.
• We also collect information from publicly available sources, purchase consumers’ personal information from data providers registered with the California Data Broker Registry, and use data research contractors who collect personal information on our behalf by phone or through internet research.

By using our services and providing your Personal Information, you agree that we have the right to disclose the categories of Personal Information we collect, as identified above, with our service provider and others for the business purposes identified below.

Purposes for collecting personal information

We use your Personal Information: 

• to carry out our obligations arising from any contracts entered into between us and consumers and to provide them with the information, products and services that they request from us;
• to provide consumers with information about other products and services we offer that are similar to those that they have already purchased or enquired about;
• to notify about changes to our service;
• to improve our site to ensure that content is presented in the most effective manner 
• to keep our site safe and secure;

Personal information we disclose to third parties

We share your Personal Information with service providers and contractors to provide our services.  The Personal Information we share with service providers and contractors can include all of the categories of Personal Information that we collect.  When we do share Personal Information, we enter into a written agreement with the service provider or contractor requiring that party to comply with all applicable laws, such as the CCPA, and restricting that party from: selling or sharing Personal Information; using the Personal Information for any purpose other than the purpose specified in the agreement; using, retaining or disclosing the Personal Information other than as specified in the agreement; or combining the Personal Information with Personal Information the service provider or contractor receives or collects in other contexts.  There are times when a service provider or contractor may engage another party to assist in providing the services; in those cases, we require the service provider or contractor to notify us in advance, and to have an agreement restricting the use, sale and sharing of the Personal Information that is similar to our agreement with our service provider or contractor

We share the identifiers described above of delegates and attendees at our conferences and online events with the conference and event sponsors, also of our subscribers and people who download sponsored content with the content sponsors, to offer consumers access to innovative solutions, research and technology improvements in their sector; competitive intelligence and information for their professional development and development of the business they represent; and to offer the opportunity to network with other business representatives.

We also share identifiers of speakers at our conferences with other conference attendees to offer speakers the opportunity to raise their professional profile and promote their business.

By using our services and providing your Personal Information, you agree that we have the right to disclose the categories of Personal Information we collect, as identified above, with our service providers for the business purposes identified above.

Personal information we sell to third parties

During the past 12 months, we have sold Personal Information of delegates and attendees to sponsors.

The categories of personal information we have sold include personal identifiers (name, job title, company name, address, work phone number, work email address).  We have sold this information to enable sponsors to offer their products and services including access to innovative solutions, latest research and technology improvements in their sector, valuable competitive intelligence and information critical to delegates’ own professional development and development of the business they represent.

Consumers are offered the opportunity to opt out of the sale of their personal information through the ‘Do Not Sell or Share My Personal Information’ link provided in this Notice.

We do not knowingly collect Personal Information of minors under 16 years of age.

Rights for California consumers

If you are a California resident, you may have certain rights. California law may permit you to request that we:

• provide you the categories of Personal Information we have collected or disclosed about you in the past 12 months; the categories of sources of such information; the business or commercial purpose for collecting or selling your Personal Information; and the categories of third parties with whom we shared your Personal Information
• provide you access to and, at your request, a copy of the Personal Information we collect about you
• delete certain information we have about you
• correct certain information we have about you
• limit the use of any sensitive information we may have about you
• provide you the categories of your Personal Information we have sold and categories of third parties to whom it was sold;
• allow you to instruct us not to share or sell your Personal Information

Your right to delete Personal Information

You have the right to request that we delete your Personal Information, subject to certain exceptions. Once we verify your request, we will erase, deidentify or anonymize the information so that it no longer is considered Personal Information under California law, and we will instruct the service providers and others with whom we shared the Personal Information to also delete the information.

We may not be able to fulfil a request to delete Personal Information if we cannot  verify the identity of the consumer making the request, or if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide services or products requested by the consumer, take action reasonably anticipated within the context of the ongoing business relationship with the consumer, or otherwise perform a contract with the consumer.
• 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 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 the consumer’s relationship with the business.
• Comply with a legal obligation.
• Make other internal and lawful uses of the information that are compatible with the context in which the consumer provided it.

If we store Personal Information on archived or backup systems, it may delay compliance with a request to delete that data until the archived or backup system relating to the data is restored to an active system or next accessed or used for a sale, disclosure, or other commercial purpose.

Your right to non-discrimination

We will not discriminate against a consumer who exercises their rights under the CCPA.  We may charge different prices or provide a different quality of goods or services, but only if the difference is reasonably related to the value provided to the consumer by the consumer’s data.

Submitting a CCPA Personal Information request

To submit a request regarding your Personal Information as described in this section, please contact us by:

• calling this toll free number +1 877 535 8574. Please note: if you are calling from outside of the United States, your call may be charged.
• completing a form on our privacy portal,
• by emailing us at dpo@customermanagementpractice.com   

We are required to verify the identity of the individual requesting access to or deletion of consumer’s personal information. To verify your identity, we will rely upon information we have previously collected about you, such as your registration information or information regarding your use of our services. If you submit a request and you are not a client or have not registered with us, then we will verify your identity by confirmation using the information we collected, such as phone number or email address. 

Authorized agent

You may designate an authorized agent to exercise a CCPA right on your behalf.  If you use an authorized agent to exercise your rights under the CCPA, we will need the following proof that you have authorized the agent to act on your behalf:

• Written proof that you have authorized the agent to act on your behalf, and separately verify your identity as described above; or
• Proof that the authorized agent holds a power of attorney to act on your behalf pursuant to California Probate Code §§ 4000-4465.

Do Not Sell or Share My Personal Information

As described above we may sell Personal Information collected from delegates and attendees to our sponsors. If you would like to request that we do not sell or share your information you may do so through this link: Do Not Sell or Share My Personal Information.

To request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes under the California's "Shine the Light" law, or to limit the use or disclosure of your sensitive personal information, please email us at dpo@customermanagementpractice.com.