California Notice at Collection and Privacy Notice

In this privacy notice, “we”, “us”, “our” and “RKD” means Robbins-Kersten Direct. Best Residents Lists is a division of RKD.

This RKD California Notice at Collection and Privacy Notice (“California Privacy Notice“) applies solely to individuals who reside in the State of California (“California Consumer” or “you“). It is delivered on behalf of RKD and our affiliates and governs certain personal information we collect from California Consumers on any website on which a link to this California Privacy Notice appears (collectively, the “Websites“) and personal information that we purchase or receive about California Consumers in order to provide services to our customers and for them to use for their own business and commercial purposes.

We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA“). Please take the time to read and understand this California Privacy Notice.

Scope

Note that because the CCPA includes certain exemptions related to the use or collection of personal information, not all personal information that we collect from or about a California Consumer is covered by the CCPA or this California Privacy Notice. For example, personal information that we collect about a California Consumer in a business-to-business context, including when a California Consumer communicates with us as an employee of a business to whom we are providing or receiving a product or service.

In addition, publicly available information, de-identified data and aggregate California Consumer information (as those terms are used in the CCPA) are not personal information for purposes of the CCPA. This California Privacy Notice does not apply to such information.

Notice at Collection

We may collect the following categories of personal information from California Consumers who visit our Website:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Commercial Information
Geolocation data
Internet or other electronic network activity information
Inferences drawn from other personal information

We may use the personal information of California Consumers who visit our Website for the following purposes:

To present our Website and its contents to you
For internal purposes, such as internal operations, improving our services, quality control and compliance
To deliver the information, products and services you requested from us
To communicate with you
To help us improve our Website and deliver a more personalized experience
To deliver advertising to you
To carry out our obligations and enforce our rights
In any other way we describe when you provide the information, or otherwise at your direction or with your consent
As permitted by law or as we may notify you

We may receive personal information from third parties about other California Consumers with whom we do not have a direct relationship. This Notice at Collection does not apply to such information, but please see “Our Collection Use and Sharing of Personal Information” for more information.

Our Collection, Use and Sharing of Personal Information

The CCPA requires us to give you specific information about the categories of personal information we collect about California Consumers, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities with whom we share it. The table below sets out our relevant practices over the last twelve months and covers the personal information we collect from California Consumers who visit our website and that which we may receive about California Consumers with whom we do not have a direct relationship.

Category of Personal Information	Categories of Sources From Which Collected	Business or Commercial Purpose for Collecting the PI	Categories of Third Parties and Other Entities With Whom We Share
Identifiers, such as IP address, mobile device id, cookies and or other online identifiers	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Categories in Cal. Civ. Code 1798.80(e)	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Characteristics of protected classifications under California or federal law, such as race, religion, sex, gender, sexual orientation, marital status, military or veteran status, nationality	-Other data brokers -Our affiliates	-For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Commercial Information, such as products or services purchased or obtained or considered, or other purchasing or consuming histories or tendencies	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Internet or other electronic network activity information, such as browsing history, search history or other information regarding your interaction with our Websites	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Geolocation data, such as city, state or country	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Professional or employment-related information	-Other data brokers -Our affiliates	-For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Education information	-Other data brokers -Our affiliates	-For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)
Inferences drawn from this information, such as preferences or other characteristics	-Directly from you, if you choose to provide this information to us -Third parties (such as service providers and vendors we engage) -Other data brokers -Automatically, such as via cookies and other tracking technologies -Our affiliates	-To present our Website and its contents to you -For internal purposes, such as internal operations, improving our services, quality control and compliance -To provide information, products and services to our customers -To communicate with you -To help us improve our Websites and deliver a more personalized experience -To deliver advertising to you -To carry out our obligations and enforce our rights -In any other way we describe when you provide the information, or otherwise at your direction or with your consent -As permitted by law or as we may notify you	-Our affiliates -Our customers, for their own business and commercial purposes -Our business partners, service providers and vendors -Legal authorities as required by law or to protect our rights -Affiliated and nonaffiliated third party as may be permitted by law (such as in connection with the sale or restructuring of all or part of our business)

How we share your personal information

In the last twelve months, we have disclosed the following categories of personal information for business purposes:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Characteristics of protected classifications under California or federal law
Commercial Information
Internet or other electronic network activity information
Geolocation data
Professional or employment-related information
Education information
Inferences drawn from other personal information

Sales of Personal Information

DMI purchases or licenses personal information about California Consumers and sells or licenses that information to its customers for their own business or commercial purposes.

We have sold the following categories of personal information for purposes of the CCPA:

Identifiers
Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
Characteristics of protected classifications under California or federal law
Commercial Information
Internet or other electronic network activity information
Geolocation data
Professional or employment-related information
Education information
Inferences drawn from other personal information

We may have sold the categories of personal information to the following categories of third parties:

Our customers to whom we provide services in a business-to-business context, for them to use for their own business and commercial purposes
Our customers who purchase information from us via our Best Residents List product for them to use for their own business and commercial purposes

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

Do Not Track Requests

We do not currently look for or respond to web browser “do not track” requests.

Right to Know

You have the right to know how we have collected, used and shared your personal information over the last twelve months. Specifically, you have the right to know:

The categories of personal information we have collected about you.
The categories of sources from which we have collected your personal information.
The business or commercial purpose for which we collect or sell your personal information.
The categories of third parties with whom we share your personal information.
The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.
The categories of personal information we have sold to third parties and the categories of third parties to whom we have sold your personal information.

In addition, you have the right to know the specific pieces of personal information we have collected about you over the last twelve months.

Right to Make a Deletion Request

You have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers to delete your personal information.

Right to Opt-Out of Sales of your Personal Information

You have the right to opt-out of the sale of your personal information.

Right to Non-Discrimination

You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.

How to Exercise Your California Privacy Rights

If you wish to exercise your rights to know or delete your personal information, please submit a request to us by calling us at (800) 334-8331 or contact us at privacy@data-management.com.

If you wish to request to opt-out of the sale of your personal information, please visit “Do Not Sell My Personal Information” or contact us at privacy@data-management.com.

Information for Authorized Agents

You can authorize a person registered with the California Secretary of State (“Authorized Agent“) to exercise your California privacy rights on your behalf. To submit a request to us as an Authorized Agent, please email us privacy@data-management.com.

Verifying Your Requests

We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the Authorized Agent acting on your behalf that is reasonable in light of the nature of the personal information requested.

We may need additional information from you to verify your request. In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your request, we will let you know.

Responding To Your Requests

We aim to promptly verify your requests and respond to your requests to know and delete your personal information within 45 days of receipt, but may require up to a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, we will let you know within the first 45 days. We respond to requests you submit to us to opt-out of the sale of your personal information within 15 business days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so if your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).

Limitations

The CCPA does not apply in full to all personal information we collect from California Consumers. As set out in “Scope” above, the CCPA is not fully applicable to some of the personal information we collect from California Consumers. Therefore, even if you are a California Consumer and submit a verifiable request, we may not be required to comply with your request.

We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.

Changes to Our California Privacy Notice

From time to time, RKD may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, please contact us at privacy@data-management.com.