California Consumer Privacy Act

This policy was last updated on September 23, 2021.

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes, and the categories of personal information the company shares.

Alternatively, the law provides that a company may comply, as Seramount does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated in the Privacy Policy, Seramount provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you choose to opt-out or at the time Seramount offers that choice, Seramount does not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: [email protected] Please include the statement “Your California Privacy Rights” in the subject field of your e-mail. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

For more information about our privacy practices, including when your information may be shared with third parties for purposes other than the direct marketing use by third parties, please review our full privacy policy.

Data protection principles

Seramount is committed to processing data in accordance with its responsibilities under the CCPA, and in particular with regard to the principles articulated therein which affirm a right to privacy, provide California consumers should be able to exercise control over their personal information, and provide that there are safeguards against misuse of their personal information.

Those principles require that where this organization collects personal information about a consumer who is a California resident (“Consumer” or hereinafter “consumer”) the Consumer has a right to request disclosure of:

  • the categories and specific pieces of personal information we collect;
  • the categories of sources from which that information is collected;
  • the business purposes for collecting or selling the information;
  • the categories of third-parties with which the information is shared;
  • disclosures about the information, and
  • the purposes for which the information is used.

Those principles also require upon verified request:

  • the deletion of personal information;
  • disclosure of the categories of information collected that we sell or disclose; and
  • the disclosure of the identity of third-parties to whom the information was sold or disclosed;

And, among other rights,

  • authorize the Consumer to opt out of the sale of personal information; and
  • prohibit discrimination against the Consumer for exercising privacy rights.
  • We are committed to supporting those rights and do so with the following policy provisions.

General provisions

  • This policy applies to all California resident consumer personal information (“Consumer Data”) processed or controlled by Seramount.
  • Personal information (“Consumer Data”) means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It includes identifiers such as a real name, alias. postal address, unique personal identifier, online identifier, Internet protocol address, email address, account name, social security number, driver’s license number, passport number or anything similar.
  • The Responsible Person shall take responsibility for Seramount’s ongoing compliance with this policy.
  • This policy shall be reviewed at least annually.
  • Seramount shall comply with an order of the California Attorney General.
  • Seramount shall seek to cure violations of the CCPA within 30 days of written notice of alleged noncompliance by a consumer. (1798.155)
  • To ensure its processing of data is lawful, fair and transparent, Seramount shall maintain a Register of Systems, which shall include a list of systems, co-controllers, processors and sub-processors.
  • The Register of Systems shall be reviewed at least annually.

Lawful, fair, and transparent processing (1798.100)

  • Where Seramount collects personal information about a Consumer, upon receipt of a verifiable Consumer request, Seramount shall disclose to that consumer the categories and specific pieces of personal information the business has collected and shall disclose and deliver promptly and free of charge. See 5(a) and (b) below for the information to be provided.
  • Where such information is disclosed and delivered, it shall, be delivered by mail or electronically, and, if delivered electronically, it shall be provided in a portable form and, to the extent technically feasible, delivered in a readily useable format that allows the consumer to transmit this information to another entity without hindrance.
  • Where Seramount collects a Consumer’s personal information, it shall, at or before the point of collection, inform consumers as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. Seramount shall not collect additional categories of personal information or use personal information collected for additional purposes without providing the Consumer with notice.

Right to be forgotten (1798.105)

  • Where Seramount collects personal information about a Consumer, it shall, upon verified request, delete any personal information about the Consumer which Seramount has collected from the Consumer from its records and direct any service providers to delete the Consumer’s personal information from their records.
  • Where Seramount collects personal information about a Consumer, it shall disclose to the Consumer the Consumer’s rights to request the deletion of the Consumer’s personal information.
  • This right to be forgotten shall not prevent Seramount from using the Consumer’s personal information to:
    • complete the transaction for which it was collected,
    • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
    • debug to identify and repair errors that impair existing intended functionality,
    • comply with the California Penal Code,
    • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest,
    • enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business, or
    • comply with a legal obligation or otherwise use the information in a lawful manner compatible with the context in which the information was given.

Right to be informed

Where Seramount collects data

  • Where Seramount receives a verified request under Section 3(a) above, Seramount shall provide to that Consumer:
    • (1) the categories of personal information it has collected about that Consumer,
    • (2) the categories of sources from which the personal information is collected,
    • (3) the business or commercial purpose for collecting or selling personal information,
    • (4) the categories of third parties with whom the business shares personal information and
    • (5) the specific pieces of personal information it has collected about that Consumer. (1798.110 ab)
  • In so providing, Seramount shall identify by category or categories the personal information collected about the consumer in the preceding 12 months by reference to the above enumerated category or categories that most closely describes the personal information collected. (1798.130.3)
  • Where Seramount collects personal information about a Consumer, it shall disclose to the Consumer the Consumer’s rights to request the deletion of the Consumer’s personal information.
  • This right to be forgotten shall not prevent Seramount from using the Consumer’s personal information to:
  • Where Seramount collects Consumer Data, Seramount shall disclose the following information concerning its practices over the past 12 months in its online privacy policy or policies and in any California-specific description of consumers’ privacy rights (or if Seramount does not maintain those policies, on its Internet Web site) and update that information at least once every 12 months:
    • (1) the categories of personal information it has collected about Consumers,
    • (2) the categories of sources from which the personal information is collected,
    • (3) the business or commercial purpose for collecting or selling personal information,
    • (4) the categories of third parties with whom the business shares personal information
    • (5) the specific pieces of personal information it collects about Consumers. (1798.110c)
  • In so disclosing, Seramount shall provide a description of consumers’ privacy rights, updated at least every 12 months, and list the categories of personal information it has collected about consumers in the preceding 12 months by reference to the enumerated category or categories that most closely describe the personal information collected. (1798.130.5ab)

Right to opt-out

  • Seramount may not sell Consumer personal information unless the Consumer has been given the right, at any time, to opt-out. (1798.120a)
  • Seramount shall not sell Consumer Data that has been sold to it by another business unless the Consumer has received explicit notice and given the opportunity not to sell that consumer’s personal information (known as the right to opt-out). (1798.115d)
  • Seramount may not sell Consumer personal information unless the Consumer has been provided notice that this information may be sold and that consumers have the right to opt out of the sale of their personal information. (1798.120b)
  • Such notice shall be in a form that is reasonably accessible to consumers and:
    • (1) provide a clear and conspicuous link on Seramount’s Internet homepage, titled “Do Not Sell My Personal Information,” to an Internet Web page that enables a consumer, or a person authorized by the consumer, to opt out of the sale of the consumer’s personal information, and
    • (2) include a description of a consumer’s rights , along with a separate link to the “Do Not Sell My Personal Information” Internet Web page in:
      • (A) online privacy policy or policies if any,
      • (B) any California-specific description of consumers’ privacy rights. (1798.135a)
  • Seramount, if it sells consumer’s personal information, shall:
    • ensure that all individuals responsible for handling consumer inquiries about the business’s privacy practices or the business’s compliance are informed of all requirements and how to direct consumers to exercise their rights,
    • for consumers who exercise their right to opt out of the sale of their personal information, refrain from selling personal information collected by the business about the consumer,
    • for a consumer who has opted out of the sale of the consumer’s personal information, respect the consumer’s decision to opt out for at least 12 months before requesting that the consumer authorize the sale of the consumer’s personal information, and
    • use any personal information collected from the consumer’s opt-out request solely for the purposes of complying with the opt-out request. (1798.135a)
  • Seramount shall allow a consumer to authorize another person solely to opt-out of the sale of the consumer’s personal information on the consumer’s behalf. (1798.135c)
  • Seramount shall, once it has received direction from a consumer not to sell the consumer’s personal information or, in the case of a minor consumer’s personal information has not received consent to sell the minor consumer’s personal information, stop selling the consumer’s personal information, unless the consumer subsequently provides express authorization for the sale of the consumer’s personal information. (1798.120c)
  • Seramount shall not sell personal information of consumers where it has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers between 13 and 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information. (1798.120d)

Right to no discrimination (1798.125 AB)

  • Seramount shall not discriminate against a Consumer for exercising its rights under California privacy law (such as denying services or charging a different price greater than the value of consumer’s data).
  • Should Seramount provide financial incentives to consumers as compensation for the collection of personal information, they shall be fair and reasonable, and Seramount will require the consumer opt-in their consent in advance in a manner which clearly describes the material terms of the financial incentive program, and which opt-in may be revoked by the consumer at any time.
  • Seramount shall provide a description of a consumer’s rights to no discrimination for exercising its rights under California privacy law in its online privacy policy or policies if the organization has an online privacy policy and in any California specific description of consumers’ privacy rights, or if it does not maintain those policies, on its Internet Web site, and update that information at least once every 12 months.

Right to notice and information

  • Seramount shall, for the purpose of receiving requests for information under the California Consumer Privacy law, make available for consumers at a minimum, two designated methods for submitting requests, including a toll-free telephone number, and if Seramount maintains an Internet Web site, a Web site address.
  • Where such a request is received, Seramount shall disclose and deliver the required information to a consumer free of charge within 45 days of receiving a verifiable request from the consumer (extended only once by an additional 45 days when reasonably necessary, provided the consumer is provided notice of the extension within the first 45- day period).
  • The information is to be delivered through the Consumer’s account with us, if the consumer maintains an account with us, or by mail or electronically at the Consumer’s option if the Consumer does not maintain an account, in a readily useable format that allows the Consumer to transmit this information from one entity to another entity without hindrance.
  • Seramount’s online privacy policy or policies or any California-specific description of consumers’ privacy rights, shall provide a description of a consumer’s rights under California privacy law and one or more designated methods for submitting requests (and shall be updated at least every 12 months).
  • All individuals responsible for handling Consumer inquiries about Seramount’s privacy practices or compliance with California privacy laws are to be informed of all requirements concerning Consumers rights to request information concerning personal information collected, sold or disclosed, Consumers’ right not to be discriminated against and how to direct Consumers to exercise their rights. (1798.130.a6)
  • Any personal information collected from a Customer in connection with Seramount’s verification of a Customer’s request is to be used solely for the purposes of verification. (1798.130.a7)

Right to access

  • Where access to customer personal data is provided to a vendor or service provider Seramount shall do so by written contract that: (1) specifies the business purpose for giving the data, (2) prohibits the retention, use or disclosure of that data on your behalf for any other purpose, (3) prohibits the retention, use or disclosure of that data for other commercial purposes, (4) prohibits the retention, use or disclosure of that information outside of the direct business relationship of the parties, (5) prohibits the sale of that data, and (6) requires compliance with California Privacy Laws as to that data including its restrictions on use, disclosure and retention.
  • Where access to customer personal data is provided to a vendor or service provider Seramount shall obtain a certification from the person receiving the data that they understand and will comply with the written contract that: (1) specifies the business purpose for giving the data, (2) prohibits the retention, use or disclosure of that data on your behalf for any other purpose, (3) prohibits the retention, use or disclosure of that data for other commercial purposes, (4) prohibits the retention, use or disclosure of that information outside of the direct business relationship of the parties, (5) prohibits the sale of that data, and (6) requires compliance with California Privacy Laws as to that data including its restrictions on use, disclosure and retention.

Questions, Concerns, and Complaints

We take our Privacy Policy seriously and we regularly review our own compliance with this Policy. If you have any questions or concerns about this Policy, or if you think that we have used your personal information in a manner inconsistent with this Policy, please contact us at: [email protected]

If we receive a complaint from you, we will contact you in an attempt to address your concerns. If we are not able to resolve a complaint, we will participate in appropriate independent recourse mechanisms as necessary.