Personal Management Consultants Privacy Policy

Last Updated: May 6, 2024

Summary

If you are a current, prospective, or former client of PMC, we need to have and use certain non-public information about you to do our job for you (the "Client Info"). We obtain Client Info from various sources and store it in our business systems subject to our security and retention policies. We disclose Client Info to others in performing our services (for example, to your selected financial service providers to facilitate your approved actions). We only use, retain, and/or disclose Client Info as part of our client services. We do not use, retain, or disclose Client Info without permission, and we do not sell Client Info to third parties. To the extent required by law, clients may request disclosure of what Client Info we have, to correct inaccurate Client Info, and/or to permanently delete Client Info (which may make it difficult or impossible for us to perform further services). Further details can be found below.

Client Privacy Policy

Personal Management Consultants, Inc. ("PMC") is a corporation headquartered in and registered under the laws of the State of California. The following privacy policy is intended for clients of the Company who are residents of California, as required by the California Consumer Privacy Act of 2018 (the "CCPA"). However, the Company uses its best efforts to ensure all clients are treated the same regardless of their place of residence.

Privileged Information

Nothing stated in this policy is intended to, nor will it, establish a privileged relationship with persons reading it. Information provided to PMC in the course of any privileged relationship enjoys a special status and may be protected by confidentiality, the attorney-client and/or accountant-client privilege, work product doctrines, and other similar protections (whether in the United States or elsewhere). Nothing in this policy detracts from any of the protections that attach to such information.

For California Residents

As required by the CCPA, this policy describes the rights available to California consumers (defined as California residents) regarding their personal information, and our practices regarding the collection, use, disclosure, and sale of personal information. These rights are not absolute and are subject to certain exceptions more fully set forth in the CCPA.

Personal Information

"Personal Information" for the purposes of this policy is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you. Pursuant to the CCPA, personal information does not include the following:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Your Rights as A California Resident

Right to Know and Access: This is your right to submit a verifiable request for information regarding the: (1) categories of personal information collected or disclosed by the Company; (2) purposes for which categories of personal information are collected by the Company; (3) categories of sources from which the Company collects personal information; and (4) specific pieces of personal information the Company has collected about you during the past twelve months. This right is subject to certain limitations under the CCPA;

Right to Delete: This is your right to request that we delete the personal information we have collected from you and maintain in our systems, subject to certain exceptions that permit us to keep your personal information for specific purposes;

Right to Non-Discrimination: This right means that the Company will not discriminate against you in any manner because you elect to exercise any of your rights under the CCPA.

Categories of Personal Information We Collect under the CCPA

In the last twelve (12) months, the Company has collected the following not all-inclusive categories and examples of personal information, as defined in the CCPA, about California consumers:

  • Personal identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers);
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information);
  • Protected classification characteristics under California or federal law (e.g., age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information);
  • Commercial information (e.g., records of personal property, services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  • Internet or other similar network activity (e.g., browsing history, search history, information on a consumer's interaction with a website, application, or advertisement);
  • Geolocation data (e.g., physical location or movements); and
  • Inferences drawn from other personal information (e.g., profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
Sources from Whom We Collect Personal Information under the CCPA

We collect personal information about you from a variety of sources in order to provide you with our services, communicate with you, and when you interact with us through electronic means or use our services, websites, and/or applications. These sources include:

  • Information you provide to us directly, such as when you contact or communicate with us, or when you establish a client relationship;
  • Information we collect automatically and through your use of our services, websites, and/or applications;
  • Information obtained from third parties; and
  • Publicly available information about you.
How We Use the Categories of Personal Information We Collect Under the CCPA

We use the personal information we collect about you to provide you with reliable, high quality services, communicate with you, make improvements to our services, investigate theft, fraud and other illegal activities, and to personalize your experience. We may use the information we collect about consumers, and the circumstances under which we may share or disclose that information may include:

  • providing, delivering, maintaining and improving the services you request, interact with, and to which you may subscribe;
  • fulfilling requests for new service or changes to your account or the services you already receive;
  • providing you with technical support and high-quality client services;
  • creating and administering a Company account, including activating our services, billing, invoicing, and debt collection activities;
  • authenticating or otherwise providing you access to Company services;
  • providing updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services;
  • managing and configuring our device(s), system(s) and network(s);
  • understanding how our services are being used, including through the creation of operational and marketing reports based on deidentified and/or aggregated service usage information;
  • informing you of additional services that may be of interest to you;
  • protecting the security of our systems, preventing fraud, detecting unauthorized reception, use, and abuse of any Company services, website, or application, and to enforce any Company policy or applicable terms of service;
  • protecting our rights, our personnel, our property, and the safety of others;
  • maintaining our accounting, tax, and other records;
  • complying with applicable federal and state laws and regulations, as well as for the general administration of our business;
  • delivering and personalizing communications with you;
  • creating internal business and marketing reports; and
  • advertising and marketing the Company subject to the applicable consent.
How You Can Submit A Request for Deletion of Your Personal Information

To protect your information, we may need to verify your identity before processing your request. In some cases we may need to collect additional information to verify your identity, such as a government issued ID.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We will use reasonable efforts to verify your identity, as well as the identity of your authorized agent to ensure that your agent has been properly authorized by you to request information on your behalf.

If we cannot verify your identity or your authorized agent's identity, we cannot fulfill your request.

To exercise one or more of your CCPA rights, please submit a request by:

  • Emailing us at info@pmcbb.com with the subject line "CCPA Request" or
  • Telephoning us at (916) 933-8251
How You Can Opt-Out of the Sale of Personal Information to Third Parties

We do not sell personal information to third parties for any purpose, including advertising or SMS messaging.

Your Right to Non-Discrimination

The CCPA prohibits businesses from discriminating against California consumers for exercising any of their rights under the CCPA. We will not discriminate against you for exercising any of these rights.

How we Protect Children's Privacy

We do not knowingly collect personal information from anyone under the age of 16.

Changes to This Privacy Policy

We reserve the right to change this policy from time to time. If we make any changes that materially affect your rights or the ways in which we collect, use, or disclose your personal information, we will notify you in advance through written, electronic, or other means, as permitted by law. Future versions of our Privacy Policy will be available on our website. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

Contact Information

To exercise your rights under the CCPA, or if you have any questions, comments, or concerns about this policy, please contact us at info@pmcbb.com or (916) 933-8251.