Last Updated Date: 12/13/19

California Consumer Privacy Act Notice for California Consumers

This California Consumer Privacy Act Notice for California Consumers (“CCPA Notice”) supplements the Privacy Policy of Phillip & Cohen Associates, Ltd. found at https://phillips-cohen.us/contact/privacy/ and applies solely to California consumers.  The California Consumer Privacy Act (“CCPA”) affords California consumers certain rights over their personal information (subject to certain exceptions).  This CCPA Notice outlines those rights and explains how such rights may be exercised.  This CCPA Notice also summarizes our data collection and sharing practices, as required by the CCPA. Terms used but not defined shall have the meaning ascribed to them in the CCPA.  For the purpose of this CCPA Notice, we refer to our websites, apps, and other products and services as “Services.”  In this notice “PCA” refers to Phillips & Cohen Associates, Ltd.

1)     What Information is Covered by this CCPA Notice? This CCPA Notice relates to PCA’s collection, use and disclosure of California consumer’s personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household.  For a specific list of the categories of personal information we collect, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.

2)    Where Do We Collect Personal Information From? For a list of the categories of sources from which we may collect personal information, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.

3)    How Do We Use Personal Information? We may use your personal information for a variety of business and commercial purposes.  “Business purpose” means the use of personal information for an operational or other notified purpose including, for example, performing services on behalf of another organization.  “Commercial purpose” refers to when we use personal information to advance our commercial or economic interests including, for example, by encouraging others to purchase our Services.  For a detailed list explaining how we may use personal information, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.

4)   Who Do We Share Personal Information With? We may share your personal information with the third parties described below and we obtain your consent prior to sharing when legally required.  For a more detailed summary of who we may share your personal information with, see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.

a)   Customers. We may share your personal information with our clients who access, use, license and/or purchase our Services (“Customers”).

b)   Service Providers. We may share your personal information with operators who work on behalf of, or with us, including service providers, processors, suppliers, agents and representatives, including but not limited to, payment processors, customer support, email service providers, event venue service providers, IT service providers, marketing service providers, advertising providers, research providers, mailing houses and shipping agents (collectively, “Service Providers”).  These Service Providers may use your personal information as provided in Section 3 (How Do We Use Personal Information?).  

c)  Affiliate Companies. We may share your personal information with our affiliates, trading names and divisions within the PCA group of companies worldwide and other related entities (collectively, “Affiliate Companies”). The affiliate companies includes Phillips & Cohen Associates, Ltd.; Phillips & Cohen (UK), Ltd.; Phillips & Cohen Associates (CANADA), Ltd.; Phillips & Cohen Associates International Ltd.; PCA Acquisitions V, Ltd. and PCA Acquisitions (UK), Ltd. t/a Invenio Financial; Phillips & Cohen Associates (Australia), Pty Ltd.; Phillips & Cohen Associates (Ireland), Ltd.; Phillips & Cohen Associates (Iberia) SL; PHILLIPS & COHEN ASSOCIATES ( IBERIA ) S.L. – SUCURSAL EM PORTUGAL; Phillips & Cohen Associates (Deutsch-land), GmbH; PCA ACQUISITIONS (DEUTSCHLAND) LIMITED; PCA Acquisitions (IBERIA) Ltd. and Invenio Financial (Australia), Pty Ltd.

d)   Disclosures Under Special Circumstances. We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm or financial loss; or (iii) to detect, investigate and help prevent security, fraud or technical issues (collectively, “Special Circumstances”).  For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as “Special Circumstance Recipients.”

 e)   Corporate Transactions.  We may transfer your personal information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets (collectively, “Corporate Transactions”). For the purpose of this CCPA Notice, third parties who receive personal information in accordance with this section shall be referred to as “Corporate Transaction Recipients.”

5)     Summary of Collection, Use, and Disclosure of Personal Information. The table below summarizes our collection and sharing practices relating to personal information, including with respect to personal information we have collected, used and disclosed in the preceding 12 months.  As shown below, we may have disclosed or sold your personal information to third parties for a business or commercial purpose in the preceding 12 months.

Categories of Personal Information CollectedCategories of Sources from which the Personal Information was CollectedBusiness or Commercial Purposes for which Personal Information was CollectedCategories of Third Parties with Whom We Share Personal InformationDisclosed for a Business Purpose
(Y/N)
Disclosed for a Commercial Purpose
(Y/N)
Identifiers such as name, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Information received from third parties including your relatives and associate.
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers/clients
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Information such as a unique personal identifier, online identifier, Internet Protocol address, email address, account name, or any other similar identifiers
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Characteristics of protected classifications under California or federal law (e.g., race, religion, gender, marital status and disability)
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • To conduct surveys and offer sweepstakes, drawings, and similar promotions
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
PCA Does not collect Biometric Information• N/A• N/A• N/ANN
Geolocation data
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Audio, electronic, visual, thermal, olfactory, or similar information (all calls are recorded)
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Professional or employment-related information
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Education information
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities, and aptitudes.
  • Information collected directly from you (including online and offline)
  • Information automatically derived from use of our Services (e.g., through cookies)
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Provide our Services
  • Develop, maintain and improve our Services
  • Process and fulfill a request or other transaction submitted to us
  • Communicate with you (e.g., notify you about changes to our Services)
  • Provide personalized services, including content and ads
  • Marketing and advertising our Services and the services of affiliates and other third parties
  • Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns)
  • For our business operations (e.g., auditing and reporting)
  • To coordinate and facilitate events (e.g., delegating booklets, badges, and passes)
  • Comply with our legal obligations
  • Promote safety, integrity and security, including to prevent fraud
  • Protecting our legitimate business interests and legal rights
  • Corporate Transactions
  • Special Circumstances
  • Customers
  • Service Providers
  • Business Partners
  • Affiliate Companies
  • Special Circumstance Recipients
  • Corporate Transaction Recipients
YY

6)    Children.  We do not sell personal information of minors under 16 years of age without affirmative authorization.

7)    Your CCPA Rights.  Subject to certain exceptions, the CCPA affords you the following rights:

a)  Request to Know. You have a right to request that PCA disclose what personal information it collects, uses, discloses, and sells. It includes a request for any or all of the following:

i) Specific pieces of personal information that PCA has about you;

ii) Categories of personal information PCA has collected about you;

iii) Categories of sources from which your personal information is collected;

iv) Categories of personal information that PCA has sold or disclosed for a business purpose about you;

v) Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and

vi) The business or commercial purpose for collecting or selling personal information.

b)  Request to Delete. You have a right to request that PCA delete your personal information that we have collected from you.

c)  Request to Opt-Out. You have a right to request that PCA not sell your personal information to third parties.  However, as mentioned above, PCA does not sell personal information.

d)  No Discrimination.  You have a right not to receive discriminatory treatment by PCA for the exercise of the privacy rights conferred by the CCPA.

8)    How to Exercise Your CCPA Rights

a)  Submitting a Request to Know or Request to Delete. You may submit a Request to Know or a Request to Delete by contacting us at this toll-free number, Customer Service Hotline at 1-866-352-5456 or via email at mail@phillips-cohen.com

b)  Submitting a Request to Opt-Out. You may submit a Request to Opt-Out by contacting us at this toll-free number, 1-866-352-5456 or by sending an email to optout@phillips-cohen.com.

c)  Verification Methods. Once a request is submitted, PCA will verify that the consumer making the request is the consumer to which the request pertains by: by comparing information the consumer provides against the information we received from our client. 

Please send written requests to:
Phillips & Cohen Associates, Ltd.
Attention: Consumer Support Unit
1002 Justison Street
Wilmington, DE 19801

You may designate an authorized agent to submit a request on your behalf by sending a power of attorney by mail or email. We require that you provide the authorized agent with written permission to act on your behalf and that the authorized agent verify their identity directly with us.

9)    Metric Requirements. As of January 1, 2021, PCA will include the following metrics in this CCPA Notice for the previous calendar year:

a)   The number of Requests to Know that PCA received, complied with, in whole or in part, and denied;

b)   The number of Requests to Delete that PCA received, complied with, in whole or in part, and denied;

c)   The number of Requests to Opt-Out that PCA received, complied with, in whole or in part, and denied; and

d)   The median number of days within which PCA substantively responded to Requests to Know, Requests to Delete, and Requests to Opt-Out.

10)    Notice of Financial Incentives. We do not offer any financial incentives for the collection, disclosure, deletion or sale of personal information.

11)    Alternate Format of CCPA Notice. To access this statement in an alternative format, please send written request to:

Phillips & Cohen Associates, Ltd.
Attention: Consumer Support Unit
1002 Justison Street
Wilmington, DE 19801

12)    Contact for More Information. If you have any questions or concerns about our privacy policies and practices, please contacts us at:  Customer Service Hotline at 1-866-352-5456 or via email  at mail@phillips-cohen.com.