Privacy Policy for California Residents

Effective Date: February 21, 2024
Last Updated On: February 21, 2024

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This Privacy Policy for California Residents supplements the information contained in ORBIS America Inc.'s Privacy Policy and Notice at Collection for California Residents and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy. Effective as of January 1, 2023, we adopt this notice to comply with the California Privacy Rights Act of 2020 (CPRA) and any terms defined in the CPRA shall have the same meaning when used in this Policy.

Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). We do not collect sensitive personal information. Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

Our Website obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from the online forms you complete and in email, text or other electronic messages between you and this Website.
• Indirectly from you. For example, from observing your actions on our Website (passive collection, incl. page clicks, time spent, or other auto-collected meta-data).
• Internet cookies and other data collection technologies we use when you access our Website.
• Social media services, such as through your use of our fan pages on Facebook and LinkedIn.
• Third party service providers and application providers. For example, collection and analysis of your information by Google for optimization and economic operation of or online offer, marketing through HubSpot, and the purchase of personal data from ZoomInfo.

We may use or disclose the personal information we collect for one or more of the following purposes:

• To present our Website and its contents to you.
• To provide you with information on products or services that you request from us, including to to fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, or subscribe to one of our events, conferences, or Webinars, we will use that personal information to respond to your inquiry or add you to one of our events, conferences or Webinars. If you provide your personal information to subscribe to the newsletter provided on our Website, we as the provider require from you an email address and information to be able to verify that you are the owner of the specified email address and that you agree to receive the newsletter (so-called double opt-in procedure).
• To fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information.
• To provide, support, personalize, and develop our Website, including to allow you to participate in interactive features of the Website.
• For any other purpose with your consent.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.
• To protect our rights and interests, and the rights and interests of other users of our products and services.
• As otherwise permitted by law.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, the Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below. We do not collect sensitive personal information.

We do not sell personal information.  We may share personal information for cross-context behavioral advertising. In the preceding twelve (12) months, Company has not sold any category of personal information to the categories of third parties with which personal information was shared as indicated in the chart below, nor has it shared personal information for cross-context behavioral advertising. Because we do not sell your personal information, we do not provide to opt-out of the sale of your personal information under this Privacy Policy for California Residents. To opt-out of the sharing of your personal information for cross-context behavioral advertising, please contact us with your request at info@orbisusa.com. You may opt out of behavioral tracking on this Website by submitting your request at info@orbisusa.com.

The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights.
Please note as mentioned above, we do not sell any personal information.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete or Correct), 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 collecting that personal information.
• The categories of third parties with whom we share that personal information.
• If we disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased (although note that we do not sell any personal information); and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

You have the right to request that we delete any of, or correct inaccuracies in, your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete or correct"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete or Correct), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion or correction request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, and take actions reasonably anticipated within the context of our ongoing business relationship with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion or correction rights for B2B personal information.

To exercise your rights to know, delete or correct described above, please submit a request by emailing us at info@orbisusa.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete or correct inaccuracies related to your personal information. If you are a California resident, you may authorize an agent to make an access, deletion or correction request on your behalf. A California resident’s authorized agent may make a request on behalf of the California resident by contacting us at the email address listed above.

You may only submit a request to know twice within a 12-month period. Your request to know, delete or correct must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. As part of our verification process, we may request that you provide, as applicable:

• For an individual (“requestor”) making a request on behalf of a California resident:
  • The requestor’s name and contact information.
  • The name and contact information of the California resident on whose behalf the request is being made.
  • A document to confirm that the requestor is authorized to make the request.  We accept as applicable, a copy of a power of attorney, or legal guardianship or conservatorship order.
• For a company or organization (“legal entity requestor”) making a request on behalf of a California resident:
  • The legal entity requestor’s active registration with the California Secretary of State.
  • Proof that the California resident has authorized the legal entity requestor to make the request.  We accept as applicable, a copy of power or attorney, or legal guardianship or conservatorship order.
  • The name and contact information of the California resident on whose behalf the request is being made.  From the individual who is acting on behalf of the legal entity requestor, proof that the individual is authorized by the legal entity to make the request.  We accept a letter on the legal entity requestor’s letterhead, signed by an officer of the organization.

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.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

We will confirm receipt of your request within thirty (30) days. If you do not receive confirmation within the 30-day timeframe, please contact info@orbisusa.com

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

We will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability 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, specifically a pass-protected encrypted file by email.

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.

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, 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.

The CCPA and CPRA permit us to offer you certain financial incentives that can result in different prices, rates, or quality levels. Participation in a financial incentive program would require your prior opt-in consent, which you would be able to revoke at any time. We do not currently provide any such financial incentives.

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. However, please note that we do not conduct business with any California resident where the business relationship is primarily for personal, family, or household purposes.

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this notice, the ways in which ORBIS America, Inc. collects and uses your information described here, in the Privacy Policy, and the Notice at Collection for California Residents, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at info@orbisusa.com.

If you need to access this Policy in an alternative format due to having a disability, please contact info@orbisusa.com or our postal address:

ORBIS America, Inc.
Attn: Human Resources
8000 Westpark Dr, Suite 620
McLean, VA 22102