Privacy Policy

SEVERSON – CALIFORNIA DISCLOSURES AND PRIVACY POLICY

The state of California requires that we provide privacy information for individuals that reside in California.  If you
do not reside in California, you can skip this document.

For California residents, here is a summary of what you will learn from these California disclosures and privacy policy:

1. Personal Information We Collect
   • Categories of personal information we collect
   • How we obtain your personal information
   • How we use your personal information
   • How long we retain your personal information
   • How we disclose your personal information
   • Sale of personal information
   • Sharing of personal information
   • Employees / Former Employees / Job Applicants
2. Your rights under the CCPA
   • Right to Know
   • Right to Delete
   • Right to Correct
   • Right to Limit Use of Sensitive Personal Information
   • Right to Opt-Out and How to Submit an Op-Out Request
   • Right to Non-Discrimination
3. Submitting a Request to Know, Request to Delete, or Request to Correct
   • How to submit a request
   • Authorized agents
   • Response timing and delivery method
4. Social Media
5. How we respond to “Do Not Track” signals
6. Changes to our California Disclosures and Privacy Policy
7. How to contact us

 

Below is the legal information we are required to share:

These CALIFORNIA DISCLOSURES AND PRIVACY POLICY govern the information collected, used, and shared relating to Severson
& Werson, APC (“Severson,” “we,” “us,” or “our”) and associated sites including www.severson.com and applies solely to visitors, users, and others who reside in
the State of California (“consumers” or “you”).  We adopt this policy to comply with 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 policy.  These CALIFORNIA DISCLOSURES AND PRIVACY POLICY supplement our Privacy Policy.

1. Personal 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 an individual consumer or device (“personal information”).

AS A COURTESY, THE FOLLOWING DISCLOSURES INCLUDE INFORMATION THAT IS EXEMPT FROM CCPA.  THE COURTESY DISCLOSURES
ARE MADE WITH A RESERVATION OF ALL RIGHTS THAT WE HAVE UNDER CCPA.

 

• Categories of Personal Information We Collect:

• “Sensitive Personal Information” such as Social Security numbers (SSNs), Driver’s license, financial
  account or card numbers, Precise geolocation, Racial and ethnic characteristics, Religious and philosophical
  beliefs, Union membership, Contents of mail, email and text messages, Genetic and biometric data;
• “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address,
  account number, Social Security Number, or government identification number;
• “Other Personal Information” such as 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, or medical information. Some personal information
  included in this category may overlap with other categories;
• “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
• “Commercial Information” such as records of personal property, products or services purchased, obtained,
  or considered, or other purchasing or consuming histories or tendencies;
• “Internet or Network Activity” such as browsing history, search history, information on a consumer’s
  interaction with a website, application, or advertisement;
• “Biometric Information” such as genetic, physiological, behavioral, and biological characteristics, or
  activity patterns used to extract a template or other identifier or identifying information, such as,
  fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, or gait;
• “Geolocation Data” such as physical location or movements;
• “Sensory Data” such as audio, electronic, or visual information;
• “Professional or Employment Related Information” such as Current or past job history or performance
  evaluations; and
• “Inferences” drawn from other personal information such as profile reflecting a person’s preferences,
  characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and
  aptitudes.

• How We Obtain Your Personal Information:

Directly from you or our clients.	You enter or provide us with information, whether online or by email, phone or document upload.
Directly and indirectly from you based on activity on our website.	For example, from submissions through our website or website usage details collected automatically.
From vendors that interact with us in connection with the services we perform.	For example, people search sites, private investigators, public records searches, or through litigation.

• How We Use Your Personal Information:

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

1. Performing services such as maintaining or servicing client relationships (including the provision of legal
   services), providing customer service, processing payments, providing advertising or marketing services, or
   providing analytic services. Examples of such activities:
   1. To fulfill or meet the reason for which the information is provided.
   2. To provide you or our clients with information, products, or services requested from us.
   3. To provide you with email alerts and other notices concerning our products or services, or events or
      news, that may be of interest to you.
   4. To carry out our obligations and enforce our rights arising from any contracts entered into between you,
      us, and/or our clients.
2. To improve our website and present its contents to you.
3. Debugging to identify and repair errors that impair existing intended functionality.
4. For testing, research, analysis and product development.
5. Auditing related to a current interaction with the consumer and concurrent transactions.
6. Helping to ensure security and integrity to the extent the use of the consumer’s personal information is
   reasonably necessary for these purposes.
7. Short term, transient use, provided that the consumer’s personal information is not disclosed to another third
   party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside
   the current interaction with the business.
8. As necessary or appropriate to protect the rights, property or safety of you, us or others.
9. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned,
   manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device
   that is owned, manufactured, manufactured for, or controlled by us.
10. To respond to law enforcement requests and as required by applicable law, court order, or governmental
    regulations.
11. To comply with our legal or regulatory obligations
12. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and
    prosecuting those responsible for that activity.
13. As described to you when collecting your personal information or as otherwise set forth in the CCPA.

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.

• How Long We Retain Your Personal Information:

Based on contractual requirements and/or legal requirements, personal information is maintained for a specified period
of time, as required by legal, regulatory, or industry requirements.  Additional information such as emails, vendor
agreements, and client records are maintained for business purposes for an indefinite amount of time.

• How We Disclose Your Personal Information:

We may disclose your personal information to a service provider, contractor, or third party. When we disclose personal
information to a service provider or contractor, we enter a contract that describes the purpose and requires the service
provider to both keep that personal information confidential and not use it for any purpose except performing the
contract or as otherwise allowed under the CCPA. We disclose personal information to third parties as follows:

• With clients we disclose Sensitive Personal Information, Identifiers, Other Personal Information,
  Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Data, Geolocation
  Data, Sensory Data, Professional or Employment Related Information, Inferences;
• With people search and private investigators we disclose Sensitive Personal Information, Identifiers,
  Other Personal Information, Protected Characteristics, Commercial Information, Geolocation Data, Sensory Data,
  Professional or Employment Related Information, Inferences;
• With software providers and data storage vendors, we disclose Sensitive Personal Information,
  Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network
  Activity, Biometric Data, Geolocation Data, Sensory Data, Professional or Employment Related Information,
  Inferences;
• With shipping providers we disclose Identifiers, Other Personal Information;
• With data analytics, network monitoring services, and incident response providers we disclose Sensitive
  Personal Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial
  Information, Geolocation Data, Sensory Data, Professional or Employment Related Information, Inferences;
• With word processing, communication applications, and calendar providers we disclose Sensitive Personal
  Information, Identifiers, Other Personal Information, Protected Characteristics, Commercial Information,
  Geolocation Data, Sensory Data, Professional or Employment Related Information, Inferences;
• With courts, arbitration associations, and mediators we disclose Sensitive Personal Information,
  Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network
  Activity, Biometric Data, Geolocation Data, Sensory Data, Professional or Employment Related Information,
  Inferences; and
• With advisors such as lawyers, accountants, auditors, banks / lenders, insurers, and consultants, we
  disclose Sensitive Personal Information, Identifiers, Other Personal Information, Protected Characteristics,
  Commercial Information, Internet or Network Activity, Biometric Data, Geolocation Data, Sensory Data,
  Professional or Employment Related Information, Inferences.
  • Sale of Personal Information:

We do not sell your Personal Information.  We do not sell the Personal Information of minors under 16 years of age.

• Sharing of Personal Information:

We do not share your Personal Information.  We do not share the Personal Information of minors under 16 years of age.
(“Sharing” means the disclosure of personal information for cross-contextual behavioral advertising.)

• Employees / Former Employees / Job Applicants:

If you are an employee, former employee, owner, officer, director, or job applicant with Severson (or a beneficiary or
emergency contract of Severson employee), please access our California Employee Disclosures and Privacy Policy with
information on your rights and how to exercise those rights.  This information was previously provided to our employees
and applicants.

2. Your rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information – the Right to Know,
the Right to Delete, the Right to Correct, the Right to Limit use of Sensitive Personal Information, the Right to
Opt-Out of the Sale of Personal Information or Sharing of Personal Information, and the Right to Non-Discrimination.
This section describes your CCPA rights and explains how to exercise those rights, if applicable.

• Right to Know:

You have the right to request that we disclose certain information to you about our collection, use, and disclosures of
your personal information (“Right to Know”).  Once we receive and verify your request, we will disclose to you:

• Categories of Personal Information Collected, Disclosed, Sold, and/or Shared
  • 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, the categories of personal information
    shared with each category of third party recipients.
  • If we sold or shared your personal information for cross-contextual behavioral advertising, the
    categories of personal information sold or shared.
• Specific Information
• The specific pieces of personal information we collected about you.

We may deny your Request to Know if we are unable to verify your identity or have reason to believe that the request is
fraudulent.  We may also deny your request if the personal information is subject to an exemption.

• Right to Delete:

You have the right to request that we delete any of your personal information that we collected and retained, subject to
certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete, de-identify, or
aggregate your personal information (and direct our service providers to do the same), unless an exception applies.

We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers
to:

• Complete the transaction for which the personal information was collected, provide a good or service requested
  by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with
  the consumer, or otherwise perform a contract between the business and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute
  those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or
  exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with
  Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that
  adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is
  likely to render impossible or seriously impair the achievement of such research, if the consumer has provided
  informed consent.
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the
  consumer’s relationship with the business.
• Comply with a legal obligation.
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the
  context in which the consumer provided the information.

Additionally, we may deny your Request to Delete if we are unable to verify your identity or have reason to believe that
the request is fraudulent.   We may also deny your request if the personal information is subject to an exemption.

• Right to Correct:

You have the right to request that we correct your personal information if it is inaccurate (Right to Correct).  Once we
verify your identity and confirm that your personal information is inaccurate, we will correct your personal information
(and direct our service providers to do the same).

We may deny your Request to Correct if we are unable to verify your identity or have reason to believe that the request
is fraudulent.  We may also deny your request if the personal information is subject to an exemption.

• Right to Limit the Use of Sensitive Personal Information:

You have the right to direct a business that collects your sensitive personal information to limit its use to uses which
are necessary to perform the services or provide the goods reasonably expected.  However, we only use Sensitive Personal
Information to provide the goods and services requested by you; to prevent, detect, and investigate security incidents;
to resist malicious, deceptive, fraudulent, or illegal actions and to prosecute those responsible for such actions; to
ensure people’s physical safety; to perform services on our behalf; to verify or maintain the quality or safety of our
products, services, and devices.

• Right to Opt-Out:

The CCPA gives consumers the right to opt-out of 1) the sale of their personal information, 2) the sharing of their
personal information for cross-context behavior advertising, or 2) for use in automated decision making.

• Sale of Personal Information:

We do not sell your personal information.  We do not sell the personal information of minors under 16 years of age
without affirmative authorization.

• Sharing Information for Cross-Contextual Behavioral Advertising:

We do not share your personal information.  Our site is not intended for or directed to minors.  We do not knowingly
share the personal information of minors under 16 years of age.

• Automated Decision-making:

The CCPA gives consumers the right to opt-out of the use of automated decision-making technology in connection with
decisions about the consumer’s work performance, economic situation, health, personal preferences, interests,
reliability, behavior, location, or movements.  However, we do not use automated decision-making technology.

• Right to Non-Discrimination:

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

3. SUBMITTING A REQUEST TO KNOW OR REQUEST TO DELETE
   • How to submit a request:

To make a Request to Know, Request to Delete, or Request to Delete, please contact us by either:

• Calling us at (877) 710-0007
• Emailing us at CCPA@severson.com

Only 1) you or 2) a person authorized by you to act on your behalf, may make a verifiable consumer request related to
your personal information. You may also make a request on behalf of your minor child.

You may only make a Request to Know twice within a 12-month period.

A Request to Know, Request to Delete, or Request to 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. Given the sensitivity of your personal information that we
  collect and retain, we will need to verify your identity with the following:
  • Declaration form signed by you under penalty of perjury (required for Requests to Know Specific
    Information),
  • Full name,
  • Full address,
  • Phone number, and
  • Email address.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

• Authorized Agents:

Before we can respond to a Request to Know, Request to Delete, or Request to Correct submitted by an authorized agent,
we need to verify not only that person or entity’s authority to act on your behalf but also verify the identity of the
authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at: CCPA@severson.com and provide the following information:

1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or
   more of the following to your request email:

• written permission from the California resident, or
• a valid power of attorney

2. To verify your identity, please attach copies of the following to your request email:

• Valid Government Issued ID (not expired) AND
• a utility bill, bank statement, or similar documentation to verify your name and address.

3. To verify the identity of the consumer for whom you are submitting the request, please provide the following in
   your request email:

• name,
• address,
• date of birth,
• email address, and
• phone number.

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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.

• Response Timing and Delivery Method:

We will acknowledge receipt of your request within 10 business days of its receipt.  We will respond to a request within
45 days of its receipt. If we require more time (up to 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. The response we provide
will also explain the reasons we cannot comply with a request, if applicable.

4. SOCIAL MEDIA

We encourage you to review your privacy options and settings with the social media platforms and networks you use to
understand what choices you have about disclosing your information through those platforms and networks with us.

5. HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

We do not respond to Do Not Track signals.

6. Changes to Our CALIFORNIA DISCLOSURES AND Privacy Policy

We reserve the right to amend these CALIFORNIA DISCLOSURES AND PRIVACY POLICY at our discretion and at any time. When we
make changes to these CALIFORNIA DISCLOSURES AND PRIVACY POLICY, we will notify you by posting the new version on our
website.

7. How to Contact Us

If you have any questions or comments about this policy, the ways in which we collect and use your personal information,
your rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact
us at:

Privacy Support Phone: (877) 710-0007

Privacy Support E-Mail: CCPA@severson.com

Website: www.severson.com

Postal Address: Severson & Werson, APC

Attn: Data Protection Officer

595 Market Street, Suite 2600

San Francisco, CA 92694

Effective Date 07/31/2023