California Consumer Privacy Act Notice
Effective Date: August 26, 2024
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This California Consumer Privacy Act Notice (“CA Privacy Notice”) supplements the information contained in NovoFlex Counsel Inc.’s (“"we," "our," or "us") Privacy Policy and applies to those Site visitors who reside in the State of California (“consumer(s) or “you”).
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This CA Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) ("CCPA") and its implementing regulations.
Information We Collect
We collect information as set forth in our Privacy Policy.
In particular, our Site has collected the following categories of personal information from consumers within the last twelve (12) months:
How long do we retain your personal information?
We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this CA Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or Our internal policy. We dispose of the information we collect in accordance with our retention policies and procedures.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
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The categories of personal information we collected about you.
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The categories of sources for the personal information we collected about you.
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Our business or commercial purpose for collecting or selling that personal information.
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The categories of third parties with whom we share that personal information.
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If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
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sales, identifying the personal information categories that each category of recipient purchased; and
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disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if the information was not received directly from. you or retaining the information is necessary for the legitimate business interest of us or our service provider(s), including maintaining business records, to comply with applicable law, or to exercise or defend claims, and to cooperate with legal enforcement.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request to privacy@NovoFlexCounsel.com or by mail to 260 Newport Center Drive, suite 100, Newport Beach, CA 92660.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and 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.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@NovoFlexCounsel.com or by mail to 260 Newport Center Drive, suite 100, Newport Beach, CA 92660.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable.
We do 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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your information
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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Deny you goods or services.
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Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
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Provide you a different level or quality of goods or services.
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Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.