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This Privacy Notice for California residents ("Notice") supplements The Innovating Edge Corporation's Privacy Notice and applies to all individuals who reside in California ("consumers," "you," or "your"). The Innovating Edge Corporation has adopted this Notice for all of its subsidiaries and related entities (collectively, "Innovating Edge," "we," "our," or "us") whose activities fall within the scope of the California Consumer Privacy Act of 2018 ("CCPA").
For the purpose of this Notice, personal information does not include information that is exempted from the CCPA, such as personal information covered by other privacy laws such as the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or the California Financial Information Privacy Act. Depending on whether you have or had a business relationship with us, the CCPA may not apply to you or all of your personal information.
Personal Information We Collect
We have collected the following categories of personal information (collected and used solely within the context of California residents' roles, as listed here) from consumers (including consumers who are job applicants to or employees, owners, directors, officers, or contractors of Innovating Edge) within the last 12 months:
· Identifiers such as real name, postal address, email address, telephone number, online identifiers, Internet Protocol address, driver's license number, Social Security number, passport number, government issued identification, or other similar identifiers;
· Protected classification characteristics under California or federal law such as age and gender;
· Financial and commercial information such as investment background and experience, as well as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
· Internet or other network activity information such as information regarding your interaction with our websites, applications, and advertisements, biometric information (such as voice authentication and call recording), and geolocation data;
· Professional or employment related information, which includes information necessary to conduct background screenings; and
· Inferences drawn from such information.
Sources of Personal Information
We collect the categories of personal information listed above from the following categories of sources:
· Directly from you or those acting on your behalf. For example, from forms you complete online or at events, when you request information about or obtain our products and services, and information that is automatically collected from internet or other network activity regarding your interaction with our websites, applications, and advertisements; and
· Government entities from which public records are maintained and other publicly available sources and unaffiliated service providers, including data resellers.
How We Use Your Information
We have used or disclosed the personal information collected for one or more of the following business purposes within the last 12 months (excluding uses or disclosures we may be prohibited from reporting under applicable law):
· To conduct our business, including providing our products and services, and, where necessary, in order to assist us in verifying your identity, and to provide support, personalize, and develop our products and services;
· To fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns, monitoring and improving our responses, and to otherwise carry out the purposes for which you provided the information;
· For our marketing and promotional event services, including market data and research. We do not share your personal information for joint marketing with other financial companies or for non-affiliates to market to you;
· To personalize your experience with our business and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our websites and mobile applications, third-party sites, and via email or text message (with your consent, where required by law);
· To perform in connection with your roles, responsibilities, and/or status as a job applicant to or an employee, owner, director, officer, or contractor of Innovating Edge, including administering payroll, benefits, maintaining compliance with policies and procedures, and to comply with health and safety and occupational health obligations;
· To help maintain the safety, security, and integrity of our business, including all products and services, and to respond, where necessary, to requests from regulators and law enforcement or as otherwise required by applicable law, regulation, court order, or similar demand;
· As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Innovating Edge's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Innovating Edge is among the assets or business operations transferred.
Personal Information Disclosed for Business Purposes
We have disclosed the categories of personal information listed above for business purposes to the following categories of parties within the last 12 months (excluding disclosures we may be prohibited from reporting under applicable law):
· Our affiliated entities and unaffiliated service providers to help conduct our business; and
· Third parties to whom you direct or authorize us to disclose your personal information, independent of or in connection with products and services we provide to you.
Innovating Edge does not and will not sell your personal information.
Your CCPA Data Rights
The CCPA provides consumers with certain data rights with respect to the personal information businesses collect. You may exercise any of the listed data rights (subject to certain exceptions and limitations), by following the "Instructions for Submitting a Verifiable CCPA Data-Rights Request" provided below.
You have "Rights to Know":
1. The specific pieces of personal information we have collected about you;
2. The categories of personal information we have collected about you;
3. The categories of sources from which your personal information is collected;
4. The categories of personal information that we have disclosed for a business purpose about you;
5. The categories of third parties to whom personal information was disclosed for a business purpose; and
6. The business or commercial purpose for collecting personal information.
You also have the right to "Request to Delete" your personal information: You may request that we delete personal information about you that we have collected from you (unless an exception applies or deletion is otherwise restricted or prohibited by law, rule, or regulation).
Instructions for Submitting a Verifiable CCPA Data-Rights Request
Please following these instructions carefully.
You may submit a verifiable request to us by either calling our toll-free number or online. If submitting your request online, please note that separate online instructions are provided below for those who are current Innovating Edge clients and those who are former or non-Innovating Edge clients. Please follow the online instructions applicable to you.
What to expect once you submit a request. We will work to confirm receipt of your request within 10 days (and provide you with information on how we will process your request, including our verification process) and to respond to your request within 45 days from the date of our receipt of your request (unless additional time is necessary, and, in such cases, we will explain to you the reason it may take more than 45 days to respond).
We may ask you to provide additional information in order to verify your identity. We will only use any additional information we collect for the purposes of verifying your identity and for security or fraud-prevention purposes. In cases where additional information is required and we are unable to contact you with the contact information you have provided, we may be unable to respond to your request.
TOLL-FREE NUMBER
Call us at +1212-461-1992 to submit your requests.
ONLINE SUBMISSIONS
Current Innovating Edge Clients: If you are a current Innovating Edge client (or an agent with your own account-access credentials acting on behalf of a current Innovating Edge client), you may submit your requests after logging into your Innovating Edge account. After you login to your account, please submit your CCPA data-rights requests through Innovating Edge's secure Message Center. From the Message Center, select Upload Document (as your written communication) and send us a message with your specific requests using "Other" as the message subject. Please do not submit your requests through the online method provided for former or non-Innovating Edge clients.
Former or Non-Innovating Edge Clients: If you are a former Innovating Edge client or not a Innovating Edge client (or an agent acting on behalf of a former or non-Innovating Edge client), please submit your requests using the Chat communication method in the top navigation bar and submit:
1. Your name, phone number, and either your email or mailing address (we may use this information you provide to assist us in verifying your identity and to communicate with you if necessary); and
2. State the specific data rights requests you are making. For example, you can state "I want to know the categories of personal information you have collected about me." Please refer to the list of available data rights above.
Please do not provide any additional information. We will contact you directly or provide you with additional instructions.
Authorized Agents
A consumer can designate an authorized agent to make a data-rights request under the CCPA on the consumer's behalf.
· Agents acting on behalf of current Innovating Edge clients: Please follow the instructions above for agents acting on behalf of current Innovating Edge clients.
· Agents acting on behalf of a former or non-Innovating Edge client: Please follow the instructions above for agents acting on behalf of a former or non-Innovating Edge client.
· Who is an "authorized agent"? An authorized agent is a person or a business entity registered with the California Secretary of State that a consumer has authorized to act on their behalf. If you are an authorized agent and submit a data-rights request on behalf of a consumer, we may require that the consumer provide you with written authorization to make the request on their behalf and verify their own identity directly with us.
Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of these data rights. Innovating Edge does not discriminate against any consumer for exercising their rights under the CCPA
CCPA Data Rights Are Not Available for Certain Personal Information
CCPA data rights are not available for personal information we collect about you in the course of you acting as a job applicant to or an employee, owner, director, officer, or contractor of Innovating Edge, including, in these contexts, your emergency contact information and personal information that is necessary for us to retain to administer benefits for another person relating to you acting as a job applicant to or an employee, owner, director, officer, or contractor of Innovating Edge. Any personal information we collect and use will only be used within the context of your role or former role in these capacities.
Questions
If you have any questions or comments about this Notice or any of Innovating Edge's other privacy policies and practices, please call +1(212) 461-1992 or go to www.Innovating Edge.com/privacy. A copy of our Corporate Privacy Notice can be found here.
Information privacy and security is a partnership and a key aspect of our business and you can read about how we protect client accounts and information by visiting Innovating EdgeSafe.
We recognize data privacy is an ongoing responsibility. We reserve the right to update or amend this Notice from time to time and any such updates or amendments will be reflected in the Notice available on our website.
We adopt this Notice to comply with CCPA Section 1798.130(a)(5).
Copyright © 2023 Innovating Edge - All Rights Reserved.
support@innovatingedge.com | Talk :212.461.1992
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