PRIVACY NOTICE SUPPLEMENT – CALIFORNIA RESIDENTS
Purpose and Application
This Supplement was adopted to comply with the 2018 California Consumer Privacy Act (“CCPA”) and is to be read in conjunction with the information contained in the standard Privacy Notice of WEDGE Capital Management L.L.P. This Supplement applies solely to individuals interacting with WEDGE who reside in the State of California.
Personal Information Defined
Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household. Personal Information includes, but is not limited to, the following: (a) identifiers, (b) select information in consumer records, (c) legally protected characteristics, (d) commercial purchasing information, (e) biometric information, (f) internet or network activity, (g) geolocation, (h) information typically detected by the senses, (i) employment information, (j) education information, or (k) inferences from the above categories used to profile. Personal Information does not include the following: (a) publicly available information from government records, (b) de-identified or aggregated consumer information, (c) 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, or(d) 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.
Collection and Sharing of Personal Information
WEDGE does not “sell” Personal Information and has not “sold” Personal Information relating to you, including within the meaning of the CCPA within the past 12 months. For purposes of this disclosure, “sell” or “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration. We may collect and store different kinds of Personal Information about you for business purposes depending on our relationship or interaction with you. 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 source Personal Information directly from our clients or their agents. Except under the limited circumstances outlined in our standard Privacy Notice, we do not intend to share Personal Information with nonaffiliated third parties.
Under the CCPA, you have specific rights regarding your Personal Information held by private companies. The following sections describe your rights and how to exercise them.
You have the right to ask us to disclose to you any Personal Information we have collected about you in the last 12 months. To exercise this right, WEDGE must verify your identity to ensure it is a legitimate request before disclosing to you the following: (a) the categories of Personal Information we have collected about you, (b) the types of sources used to collect Personal Information about you (c) if applicable, the types of third parties with which we have shared any of your Personal Information, (d) the business or commercial purpose for collecting your Personal Information, (e) the specific pieces of Personal Information we collected about you (also called a data portability request), (f) the categories of Personal Information that have been disclosed for a business purpose that each category of recipient obtained.
You have the right to request that we delete the Personal Information we have collected from and about you. To exercise this right, WEDGE must verify your identity to ensure it is a legitimate request before deleting the relevant information, unless an exemption applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: (a) provide a good or service that you requested, (b) take actions reasonably anticipated within the context of our ongoing business relationship with you, (c) otherwise perform our contract with you, (d) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us, or (e) comply with a legal obligation.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
Exercise of Rights
To exercise the access, data portability, or deletion rights described above please submit a verifiable consumer request via the contact information noted in our standard Privacy Notice. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. If an authorized agent submits a request on your behalf, you may be asked to verify your identity directly with WEDGE. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and 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 Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. 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 Format
We endeavor to respond to a verifiable consumer request as soon as practicable. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response using the contact information we have on file for that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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. 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.