Last updated May 18, 2020
This California Consumer Privacy Act Notice (“Notice”) is provided by Servion, Inc.
This Notice explains how Servion collects, uses, and discloses personal information about California residents. The Notice also explains certain rights that California residents have under the California Consumer Privacy Act (“CCPA”). This Notice explains how California residents can exercise their rights under the CCPA to request that we: (1) provide certain personal information that we have collected about them during the past 12 months, along with related information described below, or (2) delete certain personal information that we have collected from them.
The CCPA only applies to information about residents of California.
Under the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household. This information is referred to in this Notice as “Personal Information.”
CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT AND DISCLOSE
We collect and disclose Personal Information in a variety of contexts. For example, we collect and disclose Personal Information to provide individual and commercial financial products and services, and for our employment and human resource purposes.
The Personal Information that we collect, use, or disclose about a specific California resident will depend on, for example, our relationship or interaction with that individual.
During the past 12 months, we have collected the following categories of Personal Information:
- Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number, driver’s license number, and passport number
- Personal information, including contact details such as telephone number and address, financial information such as account number and balance, as well as payment card details including credit and debit card numbers.
- Characteristics of protected classes or groups under state or federal law, such as sex or marital status
- Internet or online information such as browsing history, and information regarding interaction with our websites, applications, or advertisements
- Geolocation data
- Audio, electronic, visual, thermal, olfactory, or similar information
- Professional or employment-related information
- Education information; and
- Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics
During the past 12 months, we have also disclosed the categories of Personal Information listed above for our business purposes. We have not, however, sold Personal Information that is subject to the CCPA’s sale limitations. The CCPA defines a “sale” as the disclosure of Personal Information for monetary or other valuable consideration.
WHY WE COLLECT PERSONAL INFORMATION AND HOW WE USE IT
The purposes for which we collect and use Personal Information depend on, among other things, our relationship or interaction with a specific California resident. The table below lists the purposes for which we collect and use Personal Information in different contexts.
Provide and manage products and services:
- Establish and process transactions for our products and services.
- Support the ongoing management and maintenance of our products and services including to provide account statements, online banking access, customer service, payments and collections.
Support our everyday operations, including to meet risk, legal, and compliance requirements:
- Perform accounting, monitoring, and reporting
- Enable information security and anti-fraud operations, as well as credit, underwriting, and due diligence
- Support audit and investigations, legal requests and demands, as well as exercise and defend legal claims
- Enable the use of service providers for business purposes
- Comply with policies, procedures, and contractual obligations
Manage, improve, and develop our business:
- Market, personalize, develop, as well as improve our products and services
- Conduct research and analysis, including to drive product and services innovation
- Support customer relationship management
- Evaluate and engage in mergers, acquisitions, and other transactions involving transfers of all or part of a business, or a set of assets
Support employment, infrastructure, and human resource management
- Provide benefits to employees and dependents, including healthcare and retirement plans
- Manage pay and compensation activities
- Manage and operate our facilities and infrastructure
- Process employment applications
SOURCES OF PERSONAL INFORMATION
The sources from which we collect Personal Information depend on, among other things, our relationship or interaction with a specific California resident. The information below lists the categories of sources from which we collect Personal Information in different contexts.
- From California residents directly, or other individuals acting on their behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources.
- Public records or widely available sources, including information from the media, and other records and information that are made available by federal, state, or local government entities.
- Outside companies or organizations that provide information to support activities such as fraud prevention, underwriting, and marketing.
- Outside companies or organizations from whom we collect Personal Information to support human resource and workforce management activities.
- Outside companies or organizations from whom we collect personal information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development.
CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION
The categories of third parties with whom we share Personal Information depend on, among other things, our relationship or interaction with a specific California resident. The information below lists the categories of third parties with whom we share Personal Information in different contexts.
- Outside companies or organizations with whom we share Personal Information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development.
- Government agencies including to support regulatory and legal requirements.
- Outside companies or organizations, including service providers, to whom we provide Personal Information to support human resource activities and workforce management.
- Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties.
REQUESTS UNDER THE CCPA
A California resident has the right to request that we:
- Disclose to you the following information covering the 12-month period prior to your request (“Information Request”):
- The categories of Personal Information we collected about you and the categories of sources from which we collected the Personal Information;
- The business or commercial purpose for collecting Personal Information about you;
- The categories of third parties to whom we disclosed Personal Information about you, and the categories of Personal Information disclosed;
- The specific pieces of Personal Information we collected about you; and
- Delete Personal Information we collected from you (“Deletion Request”).
If you are a California resident, a business may not discriminate against you for exercising your rights under the CCPA.
RESPONDING TO REQUESTS
Privacy and data protection laws, other than the CCPA, apply to much of the Personal Information that we collect, use, and disclose. When these laws apply, Personal Information may be exempt from, or outside the scope of, Information Requests and Deletion Requests. As a result, in some instances, we may decline all or part of an Information Request or Deletion Request related to this Personal Information. This means that we may not provide some or all of this Personal Data when you make an Information Request. Also, we may not delete some or all of this Personal Data when you make a Deletion Request.
As examples, our processing of or response to an Information Request or Deletion Request may not include some or all of the following Personal Information:
- Employment. Personal Information about an individual who is a current or former employee (team member) or job applicant, and we use that Personal Information within the context of that individual’s role as a current or former employee (team member) or job applicant.
- Business-to-Business Relationships. Certain Personal Information we collect in the course of providing a product or service to another business, or in the course of receiving a product or service from another business.
The types of Personal Information described above are examples. We have not listed all types of Personal Information that may not be included when we respond to or process Information Requests or Deletion Requests.
In addition to the above examples, we may not include Personal Information when we respond to or process Information Requests or Deletion Requests when the CCPA recognizes another exception. For example, we will not provide the Personal Information about another individual where doing so would adversely affect the data privacy rights of that individual. As another example, we will not delete Personal Information when it is necessary to maintain that Personal Information to comply with a legal obligation.
HOW TO MAKE REQUESTS
If you are a California resident, you can make an Information Request or a Deletion Request by:
- Contacting us at 1-800-766-5626;
- Submitting your request at https://www.myservion.com/contact; or
- Mailing your request to:
500 Main Street, Suite 100
New Brighton, MN 55112
CHANGES TO THIS NOTICE
We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was “Last Updated.”
SERVION, INC. PROVIDING THIS NOTICE
This Notice is provided by Servion, Inc. and its subsidiaries that either: (1) act as a business within the meaning of the CCPA, or (2) are controlled by Servion, Inc., and use the Servion name.