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California Addendum to NWPS Privacy Policy

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This California Addendum to the NWPS Privacy Policy (the “California Addendum”) applies solely to individuals who interact or have a relationship with NWPS and who reside in the State of California. We have adopted this section to comply with the California Consumer Privacy Act, 2018, as amended by the California Privacy Rights Act, 2020 (collectively, the “CCPA”). As used in this section, “personal information” means information that meets the definition of “personal information” as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.

 

What is Personal Information?

 

Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (Cal Civ. Code §1798.140 (v)). Personal Information includes, but is not limited to, the following: (a) identifiers, (b) select information in personal records, (c) legally-protected characteristics, (d) commercial purchasing information, (e) biometric information, (f) internet or network activity, (g) geolocation, (h) audio, electronic, visual, thermal, olfactory, or other similar information, (i) employment information, (j) education information, (k) inferences from the above categories used to profile, or (l) sensitive Personal Information.

 

Personal Information does not include:

 

  • Publicly-available information from government records.
  • De-identified or aggregated information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

Information NWPS collects about you

 

We may collect, use, store, and transfer different kinds of personal information about you for business or commercial purposes depending on our relationship or interaction with you which we have grouped together as follows:

Category Business or Commercial Purpose Sources of Personal information Categories of Third Parties with Whom Personal Information is Shared
Identifiers, including first name, maiden name, last name, username or similar identifier, marital status, date of birth and gender.
  • To create, maintain, customize, and secure your account(s)
  • To perform identity verification
  • To process transactions
  • To detect and prevent fraud
  • To market our products and services
  • You
  • The plan sponsor
  • From third parties on behalf of the plan, such as our payroll vendor.
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors who have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Personal Records, including the information described in Cal. Civ. Code § 1798.80(e), including name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information, medical information, or health insurance information.
  • To identify you
  • To maintain the integrity of our records
  • For client verification
  • For security and risk management, fraud prevention, and similar purposes
  • For marketing and advertising
  • You
  • The plan sponsor
  • From third parties on behalf of the plan, such as our payroll vendor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Characteristics of protected classifications under California or Federal Law, including age (40 years or older), race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, gender (including gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
  • To create, maintain, customize, and secure your account(s)
  • To perform identity verification
  • To manage our relationship with you
  • To market our products and services
  • You
  • The plan sponsor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Commercial Information, including records of products or services purchased, or considered, other purchasing or consuming histories or tendencies.
  • To create, maintain, customize, and secure your account(s)
  • To process transactions
  • To detect and prevent fraud
  • To respond to court order and legal investigations
  • To market our products and services
  • You
  • From third parties on behalf of the plan, such as our payroll vendor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Biometric Information, including genetic, physiological, behavioral, and biological characteristics. N/A N/A N/A
Internet or Electronic Data, including information regarding an individual’s interaction with an internet website, application, or advertisement.
  • For risk and security control and monitoring
  • To detect and prevent fraud
  • As necessary to provide you with access to our website
  • To respond to court order and legal investigations
  • You (either directly provided or indirectly through your use of our website)
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Geolocation Data, including physical location.
  • For risk and security control and monitoring
  • To detect and prevent fraud
  • As necessary to provide you with access to our website
  • You (either directly provided or indirectly through your use of our website)
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Sensory Data, including audio, electronic, and visual information.
  • To communicate with you
  • You
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Professional-Related Data, including work history and prior employer(s).
  • To create, maintain, and customize your account(s)
  • To manage our relationship with you
  • You
  • The plan sponsor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Education-Related Data, including the school(s) you attended and date(s) of graduation.
  • To create, maintain, and customize your account(s)
  • To manage our relationship with you
  • You
  • The plan sponsor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Inferences drawn from any of the information identified in this table to create a profile about an individual about their preferences.
  • To create, maintain, and customize your account(s)
  • To manage our relationship with you
  • You (indirectly through your interactions with us)
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.
Sensitive Information, including identifiers such as Social Security number or driver’s license number; a unique account number or account log-in in combination with any required security or access code, password, or credentials allowing access to an account; geolocation data; certain characteristics such as racial or ethnic origin and religion; and health information.
  • Create, maintain, customize, and secure your account(s)
  • Process transactions
  • Detect and prevent fraud
  • Respond to court order and legal investigations
  • Risk and security control and monitoring
  • You
  • The plan sponsor
  • Our affiliates, subsidiaries, and independent contractors engaged by us to perform services on our behalf;
  • Banking and brokerage firms to process payroll-related and/or securities transactions;
  • Third parties as requested by the plan sponsor in support of their regulatory requirements;
  • Financial advisors and investment advisors that have appropriate credentials and authorization in place with the applicable plan sponsor and/or participant;
  • Health and welfare providers in support of medical expense services;
  • Service providers in support of our daily operations, including cloud providers, customer management platforms, security providers and similar back-office services;
  • Professional advisors engaged by us, including attorneys, accounts, and auditors; and
  • Regulatory bodies, taxing agencies, and law enforcement as required under applicable law or as compelled by law or legal process.

Sharing of Personal Information

 

NWPS does not “sell” or “share” personal information relating to you within the meaning of the CCPA. For purposes of this disclosure, “sell” means the disclosure of personal information to a third party for monetary or other valuable consideration, and “share” means to share your personal information for cross-context behavioral advertising purposes.

 

Your rights under the CCPA

 

  • Under the CCPA, you have the following rights regarding your personal information processed by us.
    • You have the right to ask us to disclose to you any personal information we have collected about you in the last 12 months:
    • The categories of personal information we have collected about you,
    • The types of sources used to collect personal information about you,
    • The types of third parties with which we have shared any of your personal information (if applicable),
    • The business or commercial purpose(s) for collecting your personal information,
    • The specific pieces of personal information we collected about you (also called a data portability request), and
    • The categories of personal information that have been disclosed for a business purpose that each category of recipient obtained.
  • You have the right to ask us to correct personal information that we have collected about you.
  • You have the right to request that we delete the personal information we have collected from and about you, subject to certain exceptions.
  • You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

 

How to exercise your rights

 

In order to exercise these rights, NWPS must first verify your identity to ensure it is a legitimate request.

 

To exercise the access, correction, data portability, or deletion rights described above, please submit a verifiable request via the phone number or email address below in the “Contact Information” section of this California Addendum.

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable request related to your personal information. If an authorized agent submits a request on your behalf, you may be asked to verify your identity directly with NWPS. You may also make a verifiable request on behalf of your minor child.

 

You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable 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; 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. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

 

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response using the contact information we have on file for that account. If you do not have an account with us, 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 request’s receipt. 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 and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable 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 California Addendum

 

We reserve the right to update or change the information contained in this California Addendum at any time. In the event of a substantive change to our California Addendum, we will notify you and may request your explicit consent as necessary. We suggest you visit our website periodically to learn of any changes to our California Addendum.

 

Contact Information

 

If you have any questions pertaining to this California Addendum or if you wish to exercise your rights under applicable privacy laws, you can contact us at:

 

Phone: 888-700-0808
Email: info@nwpsbenefits.com

 

When you contact us, please provide the following:

 

  • Type of request
  • Your relationship to NWPS (client, plan participant, financial advisor, website visitor, or other)
  • Your state of residency (or country of residency, if outside of the USA)
  • Preferred method of contact (email or phone)
  • Whether you are submitting the request for yourself or on behalf of someone else

 

Last Updated: December 31, 2024