Privacy Notice for California Residents

This Privacy Notice for California Residents ("Privacy Notice") supplements the information contained in the PCM Privacy Policy (the "Privacy Policy") made available on the website located at /privacy-policy (the "Site"). The Site is owned and operated by PCM Services, LLC ("Company," "we," "us" or "our"). This Privacy Notice applies solely to residents of the State of California ("CA Consumer").

We adopt this Privacy Notice in compliance with the California Consumer Privacy Act ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA Consumer or device ("Consumer Information"). In particular, we have collected information from the following categories of Consumer Information from CA Consumer within the last twelve (12) months:

A. Identifiers - A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers.
B. Personal Information - A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected Classification and Demographics - 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).
D. Commercial Information - including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
E. Internet or other Similar Network Activity - Browsing history, search history, information on a CA Consumer's interaction with a website, application or advertisement.
F. Inferences Drawn from other Personal Information - Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
G. Sensitive Personal Information - A Social Security number, driver's license number, state identification card number, or passport number. Account log-in information, financial account, or debit or credit card number used in combination with any required security code, access code, password, or log-in credentials necessary to access an account. Precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer's U.S. mail, electronic mail, or text messages unless the business is the intended recipient and a consumer's genetic data.

Consumer Information does not include:

Publicly available information from government records.
Information that we believe has been lawfully made public by the consumer or from widely distributed media or from disclosure to a third party by the consumer where the consumer did not limit disclosure to a specific audience.
De-identified or aggregated CA Consumer information.
Information excluded from the CCPA's and CPRA'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; and
- 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.

We obtain the categories of Consumer Information listed above from the following categories of sources:

Directly from our CA Consumers. For example, from contact forms, applications and other registration forms that our CA Consumers submit to us in connection with the products and/or services that are featured by and through the Site.
Indirectly from our CA Consumers. For example, through information we collect from our CA Consumers in the course of providing our products and/or services to them.
Directly and indirectly from activity on the Site. This includes the type of browser that the CA Consumer uses (e.g., Safari or Chrome), CA Consumer's IP address, the type of operating system used by the CA Consumer (e.g., Windows or iOS) and the domain name of the CA Consumer's Internet Service Provider. In addition, we obtain certain Site usage details and analytics as they are collected automatically by us and our third-party partners.
From third parties that interact with us in connection with the products and/or services that we offer to our CA Consumers. For example, third-party entities that assist us in sending direct and electronic mail, removing duplicate information from CA Consumer lists, analyzing data and providing marketing analysis.

Retention of Consumer Information and Sensitive Personal Information

We retain all categories of your Consumer Information and Sensitive Personal Information (as described in Category G above) that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected Consumer Information and Sensitive Personal Information including:

Date of collection.
Frequency of consumer interactions with us.
Last interaction the consumer had with us.
Whether the purpose of collection has been completed.

Use of Consumer Information

We may use or disclose the Consumer Information that we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with Consumer Information in connection with your request for products and/or services, we will use that information to process your request.
To provide you with information, products or services that you request from us.
To create, maintain, customize and secure your account with us.
To provide you with e-mail, direct mail and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you.
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site's Terms and Conditions.
To improve the Site and better present its contents to you.
For customer service purposes and to respond to inquiries from you.
For testing, research, analysis and product development.
As necessary or appropriate to protect our rights, property or safety, and that of our clients and/or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Consumer Information or as otherwise outlined in the CCPA.
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 is among the assets transferred.

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

Sharing Personal Information

Subject to your right to opt out of such sharing/sale, we may share, rent and/or sell your Consumer Information: (a) with/to third parties for marketing purposes; and (b) for the other business purposes set forth above.

When we disclose Consumer Information to a third-party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the Consumer Information and requires that the third party both keep the Consumer Information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note that we do not collect information from CA Consumers that we actually know are less than eighteen (18) years of age and we do not share or sell the Consumers Information of CA Consumers that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the Consumer Information of CA Consumers that we actually know are less than eighteen (18) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of Consumer Information for a business purpose:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics and demographics under California or federal law.
Category D Commercial information
Category E Internet or other similar network activity.
Category G Sensitive Personal Information (disclosed solely as required in connection with facilitating your application.)

We disclose your Consumer Information for business purposes to the following categories of third parties:

Our affiliates (but not your Sensitive Personal Information).
Service providers.
Third parties who provide the products and/or services featured on the Site (but not your Sensitive Personal Information).
Third parties who purchase and/or license your Consumer Information for marketing purposes include: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers (but not your Sensitive Personal Information). If a third-party purchaser of your Consumer Information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt out of further sales, unless the right to resell it was secured by us at the point of collecting.
Third parties to whom you authorize us to disclose your Consumer Information in connection with the products and/or services that we provide to you.

In the preceding twelve (12) months, we have sold the following categories of Consumer Information to third parties:

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity.

In the preceding twelve (12) months, we have sold the above-referenced categories of Consumer Information (but not your Sensitive Personal Information, other than required in connection with facilitating your application) to third parties who purchase and/or license your Consumer Information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site.

Your Rights and Choices

The CCPA provides CA Consumers (California residents) with specific rights regarding their Consumer Information. This section describes your CCPA rights and explains how to exercise those rights. We endeavor to act on all opt-out requests as soon as practicable but in all cases within fifteen (15) business days of receipt of your request. To exercise any or all of these rights in regard to your Consumer Information, please submit a verifiable User request to us by either:

Call us at: (555) 555-5555
Email us at: contact@pcmgrowth.com; or
U.S. Mail to: 6th floor #6113, Brickell City Centre, 78 SW 7th St, Miami, FL 33130

Opt-Out from the Sale of Your Consumer Information

You have the right to opt out of our sale of your Consumer Information (including sensitive information) to third parties.

Opt-Out from the Sharing of Your Consumer Information

You have the right to opt out of our sharing your Consumer Information with third parties.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your Sensitive Personal Information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information), to those uses which:

are necessary to perform the services or provide the goods requested by you;
helps us ensure the security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes;
are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site;
involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and
include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Company.

You also have the right to opt out of our sharing your Sensitive Personal Information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information).

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Consumer Information over the past twelve (12) months. Once we receive and confirm your verifiable CA Consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the Consumer Information we collected about you.
Our business or commercial purpose for collecting or selling that Consumer Information.
The categories of third parties with whom we have shared that Consumer Information.
The specific pieces of Consumer Information we collected about you
If we sold or disclosed your Consumer Information for a business purpose, two separate lists disclose:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Correction of Inaccurate Consumer or Sensitive Personal Information

You have the right to request correction of inaccurate Consumer and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.

Right to Request Deletion of Consumer and/or Sensitive Personal Information

You have the right to request that we delete any of your Consumer Information and/or sensitive information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA Consumer request, we will delete (and direct our service providers to delete) your Consumer Information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your Consumer Information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

Preference Signals

You may choose to enable online preference signals, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process these signals as a request to opt out. You can learn more about GPC on their website.

Use of Authorized Agents

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA Consumer request related to your Consumer Information. We may contact you to verify that authorized agents have permission to make the deletion, correction or to know request on your behalf.

Verifiable Requests

You may only make a verifiable CA Consumer request for access or data portability twice within a 12-month period. The verifiable CA Consumer request must:

Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected Consumer Information; or (2) an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Consumer Information if we cannot verify your identity or authority to make the request and confirm that the Consumer Information relates to you. Third-party identification services may help us with verification to prevent disclosure of your Consumer Information resulting from fraudulent requests. In the event more documentation is necessary to verify your identity, we will notify you directly. Making a verifiable CA Consumer request does not require that you create an account with us. We will only use Consumer Information provided in a verifiable CA Consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA Consumer requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Consumer Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA 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.

How to Submit an Appeal

You may appeal our decision with respect to a request you have submitted by contacting us at contact@pcmgrowth.com.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA and/or CPRA rights, we will not:

Deny you goods or services;
Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you with a different level or quality of goods or services; and/or

Changes to this Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on the Site's homepage.

Contact Information

If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your Consumer Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

Call us at: (555) 555-5555
Email us at: contact@pcmgrowth.com; or
U.S. Mail to: 6th floor #6113, Brickell City Centre, 78 SW 7th St, Miami, FL 33130