Effective Date: 7/19/2021
Last Reviewed Date: 07/13/2021
Your personal privacy is of prime importance to us. CNM LLP is committed to maintaining the confidentiality of your personal information, while still being able to provide you with the professional service(s) you have grown accustomed to. We have described below the way that we deal with your personal information in keeping with the professional standards of confidentiality of our profession.
Information We Collect
We collect personal information of our employees that include applicants, current/former employees, independent contractors and Partners/Managing Directors/Officers. For the purposes of the CCPA, this would include:
- 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, and other similar identifiers.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Information We Share/Sell
We do not sell or share any personal information obtained in the course of our practice, except as required or permitted by law.
Permitted disclosure of personal information is restricted to employees and other parties who need to know that information to assist us in providing services to our employees. In all such situations, we stress the confidential nature of information being shared and that they are bound either by our professional standards of confidentiality or nondisclosure agreements where applicable.
Protecting Information, We Collect
In order to guard personal information, we maintain reasonable security measures that include physical, electronic, and procedural safeguards that are commensurate with industry best practices for cybersecurity. Please contact us if you have any questions or concerns about the confidentiality of your information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Disclosure Rights
You have the right to request that CNM LLP disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Disclosure, and Deletion Rights), 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 collection or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- 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.
Deletion Request Rights
You have the right to request CNM LLP delete any of your personal information that we collected about you and retained, subject to certain exceptions (please exceptions below). Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Disclosure, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies (please exceptions below). 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 and ensure the right of another consumer to exercise their free speech, 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Disclosure, and Deletion Rights
To exercise the access, data disclosure, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:
Data Disclosure and Deletion
c/o CNM LLP
6320 Canoga Avenue, Suite 150
Woodland Hills, CA 91367
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 disclosure twice within a 12-month period. The verifiable consumer 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.
- If any of your current information is different from that at the time it was collected from you, please provide that historic contract information to help with the verification process.
- 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 consumer request does not require you to create an account with us. 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 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 to 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 consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data disclosure 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 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.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
Accessibility Design Guidelines
Our website has been designed with the following accessibility guidelines in mind:
- The standard font used throughout the site has been chosen to be easily legible.
- Wherever possible, we use live text instead of graphics to reduce the download time of pages and increase your control.
- Our pages are designed to display without horizontal scrollbars when they are viewed at a screen resolution of 1024×768 pixels.
- No information is exclusively conveyed using color. This doesn’t mean that colors are not used to organize information; instead it means there are also other, non-color dependent ways of doing this.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Or, if you are located in the European Union, please visit the European Interactive Digital Advertising Alliance here.
California Do-Not-Track Disclosure
CNM LLP is committed to providing you with meaningful choices about the information collected on our Platform for third party purposes. That is why we provide links to the NAI “Consumer Opt-Out” link, the DAA opt-out link, and a Google opt-out link. However, CNM LLP does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations, and solutions. https://allaboutdnt.com/
6320 Canoga Avenue, Suite 150
Woodland Hills, CA 91367
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or email to us at:
6320 Canoga Avenue, Suite 150
Woodland Hills, CA 91367
Changes to Our Privacy Notice
CNM LLP reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on this Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.