California Consumer Privacy Act – Privacy Notice
Last Revised: June 15, 2020
This Privacy Notice (“Notice”) applies to individuals who live in California and whose data is subject to the California Consumer Privacy Act. This Privacy Notice does not apply to information we collect from our current residents or clients, from applicants seeking employment opportunities (or our current employees). This Notice describes what information Silverado collects that is subject to the CCPA, your rights under the CCPA, and how you can enforce those rights.
Definitions. All terms defined in the CCPA have the same meaning when used within this Notice.
Categories of Personal Information Collected. Silverado collects personal information to assist potential or actual clients obtain information and services provided by Silverado and its affiliated entities. Personal information does not include publicly available information from government records or deidentified or aggregate consumer information. Silverado may collect and retain the following information from consumers who submit inquiries through our websites, including our Live Chat Support, your mobile device, including text messages, through email, in physical locations, through the mail, and/or over the telephone. Silverado collects this Personal Information to fulfill contracts, comply with laws, and for other legitimate business interests. Silverado may disclose your information to a third-party for a specific business purpose. If you information is disclosed to a third-party, Silverado will enter into a contract with the third-party that describes the purpose of the disclosure, limits the recipient’s use of your personal information to the purposes stated in the contract, and requires the recipient to keep your personal information confidential.
| Category of Personal Information | Business Purpose for Collection of Personal Information |
| Identifiers – A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, cookies. | To provide you with information, products or services that you request from us.To fulfill any other purpose for which you provide it.For marketing purposesIn any other way we may describe when you provide the information.For any other purpose with your consent.Categories of third parties with which the PI is shared, if shared: Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), healthcare providers, External Auditors, Government Entities. |
| Commercial information – Records of products or services purchased, obtained, or considered, or other consuming histories. | To provide you with information, products or services that you request from us.To fulfill any other purpose for which you provide it.For marketing purposes.In any other way we may describe when you provide the information.For any other purpose with your consent.Categories of third parties with which the PI is shared, if shared: Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), healthcare providers, External Auditors, Government Entities. |
| Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with websites, social media pages, or advertisement. | Analyze and develop the Community’s sales and marketing strategy, determine how visitors find the Community and its website, the user’s interest regarding the Community’s services, and how to improve the Community’s website.Categories of third parties with which the PI is shared, if shared: Service Providers (e.g., website hosts and marketing firms). |
| Geolocation data – physical location. | To provide, support, personalize, and develop our Services. |
| Sensory data | Audio information recorded for quality assurance purposes. |
Silverado will not collect categories of personal information other than those outlined above.
Silverado will not use your personal information for any purpose other than outlined above. If, at a later date, Silverado intends to use your personal information for a purpose that is not described above, Silverado will directly notify you of this new use and obtain explicit consent from you to use your personal information for this new purpose.
Financial Incentives. Silverado does not offer financial incentives or price or service difference to consumers in exchange for the retention or sale of a consumer’s personal information.
Sale of Personal Information. Silverado does not and will not sell personal information of consumers.
Consumer’s Right to Know. You have the right to request that Silverado disclose what personal information it collects, uses, and discloses. This is referred to as a Request to Know. To submit a Request to Know, you can email privacyca@silverado.com or call (877) 878-9990. Requests to Know will require that you verify your identity by confirming your first and last name and associated email address, if available. Upon receiving a Request to Know, Silverado confirm receipt of the request within 10 days and provide information about how the business will process the request. For Requests to Know that seek the disclosure of specific pieces of information about you that Silverado has collected, Silverado will not disclosure any such information to the requestor if Silverado cannot verify your identity and will notify the requestor of such determination. Similarly, Requests to Know that seek the disclosure of categories of personal information about you that Silverado has collected, Silverado will not disclose any such information to the requestor if Silverado cannot verify your identity and will notify the requestor of such determination. Silverado will not provide you with specific pieces of personal information if Silverado determines that the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with the Silverado, or the security of the Silverado’s systems or networks. Silverado will not disclose your social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers pursuant to a Request to Know.
Consumer’s Right to Delete. You have the right to request that Silverado delete the personal information it collects, uses, and discloses. This is referred to as a Request to Delete. To submit a Request to Delete, you can email privacyca@silverado.com or call (877) 878-9990. Requests to Delete will require that you verify your identity by confirming your first and last name and associated email address, if available. Silverado uses a two-step process for online Requests to Delete where you must first, clearly submit the Request to Delete and then second, separately confirm that you want your personal information deleted. Upon receiving a Request to Delete, Silverado confirm receipt of the request within 10 days and provide information about how the business will process the request. Silverado may deny your Request to Delete if your identity cannot be verified.
Use of an Authorized Agent. You may authorize and agent to submit a Request to Know or a Request to Delete on your behalf. Unless the authorized agent is acting under a valid power of attorney, Silverado will require the authorized agent to submit written proof of your permission to act on your behalf and require that the authorized agent provide proof of identity. Silverado may deny a request from an agent that cannot submit adequate proof that he/she has been authorized to act on your behalf.
Consumer’s Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. You are protected by law against discriminatory treatment by Silverado for the exercise of the privacy rights conferred by the California Consumer Protection Act, which encompasses the privacy rights described herein.
Changes to Our Privacy Notice
Silverado reserves the right to amend this privacy notice at our discretion and at any time. If changes are made to this Notice, the updated Notice will be posted on Silverado’s website and with an updated revision date. Your continued use of Silverado’s website following the posting of changes constitutes your acceptance of such changes.
For more information concerning your privacy rights, you can contact the Director of Risk and Legal Affairs at (877) 878-9990 or at privacyca@silverado.com.
