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PRIVACY NOTICE

CALIFORNIA CONSUMERS

This Privacy Notice supplements the information contained in Kepro’s Privacy Policy and applies only to use of the Site by persons who reside in the State of California (“Consumers” or “you”).  Kepro has developed this Privacy Notice to address requirements of the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

YOUR RIGHTS UNDER THE CCPA

As a resident of the State of California, you have the right to obtain information about data collection and data sharing practices, request disclosure of any of your personal information which has been collected by Kepro, request deletion of your personal information to the extent allowed by law, prohibit sale of your personal data to any third party, and not be discriminated against because you have exercised your rights under the CCPA.  

PERSONAL DATA WE COLLECT AND DISCLOSE

The CCPA defines “personal information” as information that identifies, relates to or could be reasonably linked with a particular California resident or household.  In this notice, the words “Personal Data” mean personal information.

Kepro collects Personal Data you provide to us through your voluntary use and interactions with the Site. For example, we collect data when you subscribe to mailing lists, fill in forms to request information, post comments and choose how to navigate and view the Site’s content.  We may also collect Personal Data from third parties such as a legal representative who acts on your behalf, business partners that provide data to support fraud prevention and marketing services, companies that provide data or services in support of human resources and workforce and business management activities, customers of ours who provide services to you and public records.

During the past 12 months, Kepro has collected and disclosed the following categories of Personal Data:

  1. Personal unique identifiers such as full name and federal or state identification numbers such

as a Social Security number, driver’s license number and password number.

  1. Personal information such as address, telephone number, email address, banking information and health or medical information.
  2. Characteristics of protected classes or groups designated by state or federal law.
  3. Transaction history related to goods and services sold to or purchased from us.
  4. Internet and online information such as browsing history, page visits and IP addresses.
  5. Professional or employment-related information.
  6. Education information.
  7. Inferences based on information about an individual to create summaries of preference and characteristics of Site usage.

Personal information does not include information that is publicly available through local, state or federal records, de-identified or aggregated consumer information, or information that is specifically excluded by law including, but not limited to, health information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) or the California Confidentiality of Medical Information Act (“CMIA”)  or personal information covered by the Fair Credit Reporting Act (“FCRA”), the California Financial Information Privacy Act (“CFIPA”) and the Driver’s Privacy Protection Act of 1994.

HOW WE DISCLOSE PERSONAL INFORMATION

Kepro may disclose Personal Data to its affiliates, your legal representative, business partners who help us provide services you have requested, companies that provide data or services in support of human resources and workforce and business management activities, customers that provide services to you, government agencies when required to comply with regulatory or legal requirements, and outside companies in connection with routine auditing and reporting. Prior to disclosing any Personal Data with a third party, we require a confidentiality, non-disclosure or other agreement to assure protection of your Personal Data.

In the past 12 months, Kepro has not sold Personal Data for any purpose.

REQUESTS UNDER THE CCPA

As a California resident, you have the right to request information about how we have collected and used your Personal Data during the 12 months period prior to your request.   You may request information about the categories and specific elements of Personal Data we collected about you; the source(s) of Personal Data collected about you; the purpose(s) for which we used your Personal Data; the categories of third parties with whom we shared Personal Data about you; and the categories of Personal Data disclosed.  

You also have the right to request we delete Personal Data about you.

HOW TO MAKE A REQUEST; HOW WE RESPOND

Request to access and delete Personal Data may be made contacting us:

  • via email at privacy@kepro.com
  • via post to Kepro, 424 Church Street, Suite 2200, Nashville TN 37219

Kepro will respond to requests to the extent permitted by law.  In some cases, Personal Data may be exempt from or fall outside the scope of CCPA, or it may be protected under other privacy laws.  In such cases, we may not be able to fully satisfy your request for access or deletion. 

CHANGES TO THIS PRIVACY NOTICE

From time to time, Kepro will update this Privacy Notice to address changes in the services, policies and business practices, digital platforms or other business needs.  We reserve the right to amend this Privacy Notice at any time and without notice.  

The date of the most recent revision to the Privacy Notice will be stated at the bottom of this page.

Effective date: May 15, 2020