ToolGrid

Cambridge

California Consumer Privacy Policy and Collection Notice

Effective Date: 1/1/2023
Last Updated on: 6/30/2023

 

This California Consumer Privacy Policy and Collection Notice (“Notice”) supplements the information contained in Cambridge’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Cambridge Investment Group, Inc. and its subsidiaries, including Cambridge Investment Research, Inc., Cambridge Investment Research Advisors, Inc., and TBS Agency (collectively “Cambridge” or “we”) adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • 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), clinical trial data, or other qualifying research 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.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples (not intended as an exhaustive list) Collected (yes/no) Retention Period*
A.  Identifiers Your real name, alias, postal address, unique personal identifier, online identifier, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes At least six (6) years beyond the date your client relationship with us terminates.
B.  Personal information categories listed in the CA Customer Records statute (Cal.Civ.Code §1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license number or state identification card, passport number, insurance policy number, education, employment, employment history, bank account number, credit card number or any other financial information.
Some personal information included in this category may overlap with other categories.		 Yes At least six (6) years beyond the date your client relationship with us terminates.
C.  Protected classification characteristics under California or federal law Age, race, color, ancestry, national origin, citizenship, religion, 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). Yes At least six (6) years beyond the date your client relationship with us terminates.
D.  Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.. Yes At least six (6) years beyond the date your client relationship with us terminates.
E.  Biometric information 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, gait, or other physical patters, and sleep, health, or exercise data. No N/A
F.  Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. No N/A
G.  Geolocation data Physical location or movements. No N/A
H.  Sensory data Audio, electronic, visual, thermal, olfactory, or similar information Yes, we may record your phone calls to us. At least three (3) years from the date of your phone call to us.
I.  Professional/ Employment Information Current or past job history or performance evaluations. Yes At least six (6) years beyond the date your client relationship with us terminates.
J.  Non-public education information Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No N/A
K.  Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No N/A
L.  Sensitive Personal Information
  • Personal information that reveals a consumer’s:
    • Social Security, driver’s license, state identification card, or passport number;
    • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
    • Precise geolocation;
    • Racial or ethnic origin;
    • Religious or philosophical beliefs;
    • Union membership; or
    • Genetic data.
  • The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
  • The processing of biometric information for the purpose of uniquely identifying a consumer.
  • Personal information collected an analyzed concerning a consumer’s health, sex life, or sexual orientation.
 Yes, but without the purpose of inferring characteristics about a consumer. At least six (6) years beyond the date your client relationship with us terminates.

*Financial industry rules and regulations require us to retain certain client information for the duration of your client relationship with us, plus at least six (6) years following the termination of that relationship.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you when you call, write, or send information to us.
  • From your Financial Professional. For example, forms you complete or products and services you purchase through your Financial Professional.
  • From other companies and third parties with whom you do business and with whom we have agreements in order to service and maintain your accounts at Cambridge.


Use of Personal Information

We do not sell the information we collect. We may use or disclose the personal information we collect for one or more of the following purposes:

  • To comply with legal and regulatory requirements
  • To create and maintain a client relationship with you, including to service and maintain your accounts with us
  • To perform identity verification
  • To process transactions
  • To detect and prevent fraud
  • To record telephone interactions for regulatory requirements
  • To enhance the quality of client interactions
  • For internal training purposes

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.


Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category Category of Third-Party Recipients
Business Purpose Disclosures  Sold
A. Identifiers Service providers and Affiliates No
B. Personal information categories listed in the CA Customer Records statute (Cal.Civ.Code §1798.80(e)) Service providers and Affiliates No
C. Characteristics of Protected Classifications Not disclosed No
D. Commercial Information Service providers and Affiliates No
E. Biometric information Not collected / Not disclosed No
F. Internet or other similar network activity Not collected / Not disclosed No
G. Geolocation data Not collected / Not disclosed No
H. Sensory data Not disclosed No
I. Professional/Employment Information Service providers and Affiliates No
J. Non-public education information  Not collected / not disclosed No
K. Inferences drawn from other personal information Not collected / not disclosed No

We do not sell your personal information or share it for purposes of cross-context behavioral advertising or for purposes of inferring characteristics. 

We do not sell or disclose deidentified patient information exempt from the CCPA to third parties. 


Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.


An individualized right to know.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • 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 or selling 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, a list stating the disclosures for a business purpose and identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

 

Right to Delete.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • 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 information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

 

Personal information sale prevention rights.

You have the right to direct us to stop selling your personal information.  We do not sell your personal information. 

 

Freedom from 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 a different price, provide you with a different level or quality of goods or services, or suggest that you may receive a different price or a different level of quality of goods or services. 

 

Correct inaccurate personal information.

You have the right to require that we correct any inaccurate personal information we collect.

 

Opt-out of sharing personal information for cross-context behavioral advertising purposes.

You have the right to direct us to stop sharing personal information for the purpose of cross-context behavioral advertising.  We do not share personal information for this purpose.

 

Restrict sensitive personal information processing.

You have the right to limit the way we use and disclose sensitive personal information to just actions necessary to perform specific purposes listed in the CCPA.  We do not use or disclose sensitive personal information.   


Exercising Your Rights to Know or Delete

To submit a request regarding your personal information, please contact us at 888-245-0452 or email oad-processing@cir2.com. 

We will confirm receipt of your request within ten (10) days. We have forty-five (45) days to respond to your request and may extend that timeframe as reasonably necessary. We will notify you of any extension.

The safety and security of your personal information is important to us. We will not release any of your personal information or data without verifying your identity. We have implemented certain security protocols to protect your personal information and to prevent fraud. In order to verify your identity, we will ask certain questions regarding the personal information we have received from you through the ordinary course of doing business. In some instances, additional information may be required. If we are unable to verify your identity, if you refuse to provide the information requested for verification purposes, or we are unable to contact you to complete any of the required verification steps, we will not provide your personal information in response to the request. 

In order to verify your identity, you may be asked for some or all of the following information:

  • First and Last Name
  • Legal Address (street, city, state, zip code)
  • Mailing Address (street, city, state, zip code) if different than your legal address,
  • Email Address 
  • Phone Number
  • Account Number(s)

If submitting your request via email, please include the specific data request you are making, such as, “I want to know the specific pieces of personal information Cambridge has collected about me.” Please do not provide any private or confidential personal information via email. We may provide you with additional instructions to complete your request. We will reach out to you directly to verify your identity.

If you are an authorized agent (such as a person or entity registered in California that has been authorized to act on behalf of our client) making a data request under the CCPA regarding the information of a Cambridge client, we may require additional information from you. Further, if we do not already have documentation on file authorizing you to make such a request, we will require written authorization from our client in order to provide you with the information. In some instances, we may also require that our client directly verify their own identity according to our information security protocols. If these steps are not met as required, requests for personal information will be rejected.

Changes to Our Privacy Policy and This Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on this website and update the Notice’s effective date. Your continued use of our website and our services following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

For any questions regarding this Notice, or any other questions regarding your personal information, please call 888-245-0452 or visit https://www.joincambridge.com/legal/privacy/privacy-policy-statement/