Crawford Group Privacy Notice for California Residents

Effective Date: January 1, 2023

This Privacy Notice for California Residents supplements the information contained in our Website Privacy Policy above and applies solely to natural persons residing in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 which was amended by the California Privacy Rights Act of 2020 (together, “CCPA”). Any terms not defined herein have the same meaning set forth in the Website Privacy Policy.

Categories of Personal Information We Collect and the Sources

Our Websites may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Personal Information does not include:

• Publicly available information.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope.

Our Websites may collect the following categories of Personal Information:

Our Websites obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete on our Websites and other direct interactions you have with us.
• Indirectly from you. For example, from observing your actions on our Websites.

Your Rights and Choices

The CCPA provides consumers with the following rights with regards to the Personal Information we collect:

Right to Know and Access Personal Information

You have the right to request a copy of your Personal Information that we collected in the past 12 months. We will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources of the Personal Information we collected about you.
• Our business or commercial purpose for collecting, disclosing, sharing, or selling that Personal Information.
• The categories of third parties with whom we shared that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we shared, sold, or disclosed your Personal Information, separate lists of the categories of Personal Information we have shared, sold or disclosed in the preceding 12 months.

Right to Know About Disclosure, Sharing and Sale of Personal Information

You have a right to know how we use your Personal Information and whether, and to whom, we disclose, share, and sell such Information.

Disclosure and Use of Personal Information

We may use or disclose to third parties the Personal Information we collect for one or more of the following business purposes:

• As part of the subscription process to our services, to provide our services to you, to personalize your experience with us, to keep you informed of our products and services that may be of interest to you, and to reach you regarding issues concerning your use of our services.
• For information technology support, to administer our services, and to gather demographic information.
• To respond to a lawful request by public authorities, such as to comply with a subpoena, or similar legal process, including to meet national security or law enforcement requirements.
• Under a good faith belief that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request.
• In connection with a corporate sale, merger, reorganization, dissolution or similar event (in this case, Personal Information may be a part of assets transferred from our company to the acquiring company).
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for business purposes:

Identifiers; commercial information; internet activity information 

Sale and Sharing of Personal Information

We have not sold nor shared Personal Information in the preceding twelve (12) months.

Right to Delete

You have the right to request that we delete Personal Information that we collected from you subject to certain exceptions.

Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate Personal Information maintained by us.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Subject to the exceptions provided for in the CCPA, 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.

Exercising Your Rights

To exercise the rights afforded to you under the CCPA, please submit a verifiable consumer request to us by either:

• Emailing us at privacy@crawfordgroup.com; or
• Calling us at 1-408-343-0200; or
• Writing to us at Crawford Communications Group, Attention Privacy Department, 51 E. Campbell Avenue, Suite 110-G, Campbell, CA 95008

Only you or a person registered with the California Secretary of State that you authorize 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.

We are only obligated to respond to a verified consumer request 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.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. 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 consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We will not charge a fee to process or respond to your verifiable consumer 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.

Changes to Our 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 notice on our Websites and update the notice’s 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, requests, or comments about this notice, the ways in which we collect and use your information as above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows:

• Email: privacy@crawfordgroup.com
• Phone: 1-408-343-0200
• Postal Address: Crawford Communications Group, Attention Privacy Department, 51 E. Campbell Avenue, Suite 110-G, Campbell, CA 95008