Contact us today: (831) 424-1414

Make a Payment

Privacy Policy for Consumers

California Consumer Privacy Notice

Please review the terms of the privacy notice set forth below carefully.  This privacy notice addresses information collected and disclosed in the preceding twelve (12) months.

1. Our Commitment to Your Privacy

At Noland, Hamerly, Etienne & Hoss (NHEH), your privacy and the protection of your personal and financial information is our priority.  NHEH complies with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”), which create consumer rights for individuals who are California residents relating to the access to, deletion of, and sharing of personal information that is collected by businesses.  

2. California Consumer Privacy Act/California Privacy Rights Act

The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”) set forth specific obligations for businesses processing personal information of California residents.  “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual.  

Pursuant to the CCPA and the CPRA, NHEH is required to provide consumers who are California residents a notice that identifies the categories of personal information that may be collected, and why NHEH collects that information.

This California Consumer Privacy Notice (“Notice”) is intended to notify you of our privacy practices as required by the CCPA and the CPRA.

This Notice applies only to individuals residing in the State of California who are considered consumers from whom we collect “Personal Information” as set forth in this Notice.

3. What Personal Information Does NHEH Collect about California Consumers?

You may be asked to provide personal information in a variety of ways including by email, over the phone, on our website, on your mobile device, in physical locations, and in person.  Listed below are the categories of personal information that NHEH has or may have collected and processed about you in the preceding twelve (12) months.  

Identifiers:  

  • Name
  • Nickname or alias
  • Title
  • Alias
  • Signature
  • Mailing address 
  • Email address
  • Organization
  • Job responsibilities
  • Gender
  • Telephone numbers
  • Account number
  • Online identifier
  • Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual.

A “unique personal identifier” is a persistent identifier that can be used to recognize a consumer, or a device that is linked to a consumer, over time and across different services, including, but not limited to, a device identifier, an Internet Protocol address, cookies, beacons, pixel tags, or similar technology; unique pseudonym or user aliases; telephone numbers; or other forms of persistent identifiers.

Internet or Other Electronic Network Activity Information:

  • Browsing history
  • Search history
  • Information regarding interaction with an internet website, application, or advertisement
  • Geolocation data related to use of an internet website, application, or physical access to a NHEH office location

Professional or Employment-Related Information:

  • Work history
  • Professional memberships
  • Professional certifications
  • Internal and external contact information

Commercial Information:

  • Records of personal property
  • Records of products or services purchased, obtained, or considered
  • Other purchasing or consuming histories or tendencies

Client Service Information:

  • Personal information received from clients regarding their employees or other individuals known to clients
  • Invoicing details and payment history
  • Client feedback

Education Information:

  • Institutions attended
  • Education records
  • Degrees
  • Certifications

Registration Information:

  • Information necessary to process or respond to
    • Event/Seminar Registration
    • Requests to download information
    • Usernames/Passwords

Device Date:

  • IP Address
  • Unique Device Identifiers
  • Cookies
  • Other data linked to a device
  • Data about the usage of NHEH’s website

Inferences:

  • Information drawn from any of the personal information categories referenced above to create a profile about a consumer.

4. Sensitive Personal Information

You may also supply us with, or we may receive, the following sensitive personal information:

  • Financial, account, or billing information
  • Tax identification number
  • Social security number
  • Driver’s license number
  • Passport number
  • Credit/debit card information
  • Responses to particular questions (e.g., the name of your school)
  • Username and password
  • Internet Protocol (IP) address
  • Unique personal and/or online identifiers
  • Protected classifications under California or federal law (race, religious creed, color, national origin, ancestry, mental disability, physical disability,  medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, reproductive health decision making, veteran status, military status)
  • Date of birth
  • Place of birth
  • Records of client instructions or other matters discussed
  • Transcripts or written notes of client interviews

5. Methods of Collecting Your Personal Information and Sensitive Personal Information

We may collect information through the following methods:

  • Directly from you from, for example, forms you complete on our website or in person, emails you send, information provided by phone or in person.
  • Indirectly from you by, for example, observing your actions on the NHEH website.
  • From third parties, from our website, or through the use of Cookies.
  • From conference calls and video conferences with clients and third parties.
  • From counterparties to transactions or disputes.
  • From interviews with clients.
  • From employers.
  • From agents or professional advisors authorized to disclose data on behalf of the individual.
  • From publicly available or subscription-based sources.
  • From voicemail messages.
  • From audio and/or video recordings of meetings, interviews, or depositions.

6. To Whom Does NHEH Sell Your Personal Information and Sensitive Personal Information?

  • NHEH does not sell your personal information or your sensitive personal information.

7. With Whom Does NHEH Share Your Personal Information and Sensitive Personal Information?

For the purposes set forth below at section 8, NHEH shares your personal information only as needed with the following: 

  • Suppliers, service providers, and contractors where necessary to perform functions on behalf of NHEH including, but not limited to, recruiting efforts and meeting our business needs and obligations
  • Opposing parties, their counsel, courts, administrative agencies, arbitrators, mediators, and others as necessary to represent NHEH clients and to respond to court orders, subpoenas, civil discovery requests, other legal process, or as otherwise required by law
  • Government or administrative entities when required by law including, but not limited to, Equal Employment Opportunity Commission and California Civil Rights Department to respond to employment claims and charges
  • As required to comply with the law or to protect the rights, property, or safety of NHEH, our users, or others
  • Outside freight companies for delivery purposes
  • Outside courier services for delivery purposes.

8. Purposes for Collecting Your Personal Information and Sensitive Personal Information

NHEH collects the personal information and sensitive personal information identified in Sections 3 and 4, above, for the following reasons:

  • To secure and protect your identity as you navigate our website
  • To meet the purpose for which you provided the information  
  • To conduct conflicts checks
  • To provide legal advice, business services, and to respond to inquiries
  • To manage our business operations and administer our client relationships
  • To maintain your information including, but not limited to, customizing and securing your information or account with NHEH
  • To support and develop NHEH’s website
  • To investigate and address your concerns, and to monitor and improve our responses
  • To maintain security on the NHEH website including hosting and maintenance of computer systems and infrastructure; managing NHEH’s software and hardware computer assets; systems testing; training; and monitoring email and internet access 
  • To provide relevant marketing
  • To address compliance and legal obligations (i.e., checking identity of new clients, preventing fraud/money laundering, protecting the security of NHEH’s networks, devices, and information)
  • To comply with NHEH’s legal and/or best practice obligations (i.e., equal employment opportunity laws, monitoring diversity and inclusion)
  • Mandatory disclosures and legal claims in compliance with applicable law or regulatory requirements such as legal (state and federal) and internal company reporting obligations and record retention requirements, compliance with any subpoena, court order or other legally binding request or process.

9. How NHEH Protects Your Personal Information and Sensitive Personal Information.  

NHEH processes and protects your personal information and sensitive personal information by maintaining electronic, physical, and procedural safeguards.  We use computer safeguards such as data encryption; we enforce physical access controls to our buildings and files; and we authorize access to your personal information and sensitive personal information only for those employees who require it to fulfill their job responsibilities.

10. Your Rights Regarding the Personal Information and Sensitive Personal Information

  • Right of Access:  You have the right to access personal and/or sensitive personal information which NHEH may collect or retain about you.  If requested, we shall provide you with a copy of the personal information or sensitive personal information which we collect as permitted by the CCPA/CPRA.
  • Right to Know: You have the right to request that we disclose the following about your personal information and/or sensitive personal information: 
  • The specific personal information or sensitive personal information we may collect 
  • The categories of personal information or sensitive personal information we may collect
  • The categories of sources from which we may collect your personal information or sensitive personal information 
  • The business purpose(s) for collecting or sharing your personal information or sensitive personal information 
  • The categories of personal information or sensitive personal information we may disclose for business purposes  
  • The categories of third parties with whom we may share your personal information or sensitive personal information. 
  • Sale of Personal Information or Sensitive Personal Information:  NHEH does not sell personal information or sensitive personal information within the meaning of the CCPA/CPRA. 
  • Sharing/Disclosure of Sensitive Personal Information. You have the right to limit how your sensitive personal information is disclosed or shared with third parties, as defined in the CCPA/CPRA unless otherwise provided by law. 
  • Right to Deletion. In certain circumstances, you have the right to request the erasure of your personal information or sensitive personal information. Upon verifying the validity of a deletion request, we will delete your personal information or sensitive personal information from our records, and instruct any service providers or third parties to delete your information, when applicable.  The right to deletion does not extend to personal information and sensitive personal information that NHEH is legally required to maintain.
  • Right to Correct/Right to Rectification. In certain circumstances, you have the right to request correction of any inaccurate personal information or sensitive personal information. Upon verifying the validity of a verifiable consumer correction request, we will use commercially reasonable efforts to correct your personal information or sensitive personal information as directed, taking into account the nature of the personal information or sensitive personal information and the purposes of maintaining your personal information or sensitive personal information. 
  • Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. 
  • The above requests may be made by calling 831-424-1414, ext. 266, or emailing [email protected].  

11. Non-Discrimination

If you are a California resident, you can exercise any of your rights as described in this Notice and under applicable privacy laws by using the contact information provided in this Notice. We will not discriminate against you for exercising such rights. 

12. Verifying Requests  

When you make a request to us, we will require your name, e-mail, phone number, and address. We will attempt to match our records based on that information. Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm their identity.

13. Timelines for Responding to Requests

No later than ten (10) days after receiving a request set forth in section 10, herein, NHEH will confirm receipt of the request and provide information about how it will process the request.  NHEH will respond to requests no later than 45 calendar days after receiving the request.  If additional time is needed to respond, we will provide notice and an explanation and will request up to an additional 45 calendar days to respond.  If we are unable to verify the individual making the request, NHEH may deny the request. 

14. Updates

This Notice will be updated at least once every twelve (12) months to reflect changes in NHEH’s business, legal, or regulatory obligations.  Please check this Notice periodically for changes.  NHEH will not collect additional categories of your personal information or sensitive personal information, or use your personal information or sensitive personal information already collected for additional purposes without providing you with a notice of our intent to do so.  

15. Retention Policy

NHEH retains your personal information and sensitive personal information for a reasonably necessary period of time.  When state or federal law specify record retention requirements for certain records, NHEH complies with those laws.

16. Use of Cookies and Online Behavior

In some portions of the website, so-called “cookies” are used in order for us to improve the efficiency of your individual use of the website and to enhance your browsing experience. Cookies are identifiers that our server may send to your computer in order to identify the computer being used for the duration of the session. Most browsers are set up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. If you disable cookies, some features may be disabled, and some of our services may not function properly. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

In order to track web site usage, we use Google Analytics, which does not allow the collection of personal identifiable information. For information on Google Analytics, click here. You can opt out of making your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on.

17. COPPA (Children’s Online Privacy Protection Act)

In light of the importance of protecting children’s privacy, NHEH does not collect, process, or use on the website any information relating to an individual whom we know to be under 13 years of age.  Further, the website is directed to people who are at least 13 years of age or older.  As such, we are in compliance with the requirements of COPPA.

Questions

If you have questions regarding this Notice or about your rights regarding your Personal Information or Sensitive Personal Information, or if you have concerns about the safety or possible misuse of your Personal Information or Sensitive Personal Information, please contact us by email at [email protected].