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CALIFORNIA RESIDENTS

FOR CALIFORNIA RESIDENTS ONLY

Effective January 1, 2020

Your Rights and Choices

The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers residing in California (“California Consumers”) with specific rights regarding their personal information. This Notice supplements the Synergy Online Privacy Policy and applies solely to California Consumers.  

Personally Identifiable Information (“personal information”) is defined for purposes of this section of the Policy as information that identifies, relates, describes, references, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, you as an individual. Personal information includes information collected directly from you if you choose to purchase products, use certain services available on our sites or personal information that you voluntarily provide, such as information included in response to a questionnaire or survey, or if you apply for a job on our Careers sites.

Under the CCPA and the unique consumer rights described below, personal information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”); and
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

Sharing of Personal Information

We may disclose personal information we collect for one or more of business purposes described in the Policy. 

In the preceding twelve (12) months, we have not sold any of your personal information unless a transfer of this information to an advisor, broker or third-party insurance marketer was authorized by you.  

Personal information covered by the CCPA shared in the preceding twelve (12) months includes:  

  • Name, mailing address, telephone number, email address and date of birth; and 
  • Demographic and career history if you applied for a position on our Careers sites

We do not collect or share the personal information of any covered consumers under the age of 16.

Access to Specific Information and Data Portability Rights

Subject to the exceptions set forth in the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your personal information covered over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling your personal information;
  • The categories of third parties with whom we share personal information;
  • The specific pieces of personal information we collected about you;
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You can make this request by clicking here and completing the linked form CCPA Form or by contacting us at the following toll-free number: (888) 995-1256.

Deletion Request Rights

Subject to the exceptions in the CCPA, you have the right to request that we delete any of your personal information collected from you and retained by us. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
  • Comply with a legal obligation; and
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You can make this request by clicking here and completing the linked form CCPA or by contacting us at the following toll-free number: (888) 995-1256.

Exercising Access, Data Portability, and Deletion Rights

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information, commensurate to the type or sensitivity of the information you are requesting, that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request in 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up 90 days), we will inform you of the reason and extension period in writing. 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 consumer 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, specifically by electronic mail communication.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 

Changes to Our Privacy Notice

We reserve the right to amend this California privacy notice at our discretion and at any time. When we make changes to this California privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

The effective date of the rights for California residents described in this California privacy notice is January 1, 2020. Changes to this California privacy notice will not affect our use of previously provided personal information.

Contact Information

If you have any questions about this California privacy notice, the ways in which we collect and use your information described in this notice, your choices and rights regarding such use, please feel free to contact us as follows:

  • Sending an e-mail request to: compliance@s1l.com 
  • Sending a letter via US Mail to:

    S1L, Inc. 

3131 Camino Del Rio N., Suite 150

San Diego, CA 92108