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Supplemental Privacy Statement (California Residents Only)

Updated:December 10, 2020

California "Shine the Light" Law/Your California Privacy Rights

California Civil Code § 1798.83 (the "Shine The Light" law) permits consumers, who are California residents, to request and obtain from us once a year, free of charge, information about the categories of Personal Data (as the Shine the Light law defines), if any, that we disclosed in the preceding calendar year to third parties for those third parties' direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, please contact us via our email address below.

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) applies to most businesses, enhances data privacy rights for California residents, and requires businesses to be transparent about how they collect, share, and use California consumers’ personal data.

California Consumer Rights under the CCPA

Disclosure. A business must disclose the personal data collected, sold, or disclosed for a business purpose about a consumer.

  • A business that collects personal data needs to disclose the following in response to a verified consumer request:
    • Categories of personal data the business has collected about the consumer.
    • Categories of sources from which the personal data is collected.
    • Business or commercial purpose for collecting personal data.
    • Categories of third parties with which the business shares personal data.
    • Specific personal data the business has collected about the consumer.
  • A business that sells a consumer's personal data or discloses a consumer's personal data for a business purpose needs to disclose the following in response to a verified consumer request: Categories of the following:
    • Personal data the business has collected about the consumer.
    • Personal data the business has sold about the consumer.
    • Third parties to which the personal data was sold.
    • Personal data sold to each third party (if the business has not sold consumers' personal data, it shall disclose so).
    • Personal data the business has disclosed about the consumer for a business purpose (if the business has not disclosed consumers' personal data for a business purpose, it shall disclose so).

Note: The CCPA’s definition of “sale” is broad and includes sharing practices common among online businesses.

Access. A business that collects a consumer's personal data must, at or before the point of collection, inform the consumer of the categories of personal data to be collected and how the categories of personal data shall be used. Additionally, a business must disclose and deliver the personal data collected about the consumer in response to a verifiable consumer request.

Deletion. A business must delete the personal data collected about a consumer and direct service providers to delete the consumer's personal data in response to a verified consumer request, subject to certain exceptions.

Antidiscrimination. A business must not discriminate against a consumer who exercises any CCPA rights. However, a business may charge different prices or provide a different quality of goods or services if the difference is reasonably related to the value provided to the consumer by the consumer's data and may offer financial incentives to a consumer for the collection, sale, or deletion of personal data on a prior opt-in consent basis.

Opt Out and Website Requirements. A business that sells consumers' personal data to third parties needs to notify consumers thereof and that the consumers have the right to opt out of the sale of their personal data. A business must provide a link on its internet homepage that links to a webpage that allows a consumer to opt out of the sale of their personal data. A business must not sell a consumer’s personal data if the business has actual knowledge that the consumer is less than age 16, unless either: (a) the consumer is between ages 13 and 16; or (b) the consumer's parent or guardian for a consumer who is younger than 13, has authorized the sale of the consumer's personal data.

Privacy Policy Requirements. A business must describe in its online privacy policy or in any California-specific description of consumer privacy rights the following, which must be updated at least once every 12 months:

  • Consumers' rights under the CCPA, including the right to opt out of the sale of the consumer's personal data and a provide separate link to the page;
  • The methods for submitting consumer requests; and
  • A list of the categories of personal data that the business has collected, sold, and disclosed about consumers for a business purpose in the preceding 12 months.

California Do Not Track Disclosures

We do not currently respond to browser Do Not Track signals or other browser or device based mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. Unless and until the law requires us to respond to browser Do Not Track signals, we will not respond to those signals as an opt out, but if we do so in the future, we will describe how we do so here. However, we do provide consumers with the ability to manage their cookie choices as described in our Cookie Policy For more information on Do Not Track, please visit www.allaboutdnt.com.

Third Party Links

Our Websites or Services may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms, or may redirect you off our Website away from our Services to other websites for information or other services. This Privacy Policy only applies to information collected by our Websites and Services. We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

California Privacy Act Statement

This EKWB California Privacy Statement supplements EKWB’s Privacy Policy and applies solely to California residents who visit or use our website. If you are a California resident, the California Consumer Privacy Act (“CCPA”) grants you various rights regarding your personal data.

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 consumer or device (“Personal Data”). In particular, the table below identifies categories of Personal Data we have collected the following from consumers within the last twelve (12) months.

The CCPA’s definition of “sale” is broad and includes sharing practices common among online businesses. The following chart also shows the types of personal identifiers that we may have “sold” in the previous twelve (12) months. Under the CCPA, we may disclosed Personal Data in the categories below from consumers and users of our Services within the last twelve months where such disclosure may fall within the CCPA’s definition of a "sale." When we disclose that we may have “sold” Personal Data, it means that we may have received some kind of benefit to our company in return for sharing Personal Data, it does not necessarily mean we received any money in exchange. While, without your consent, EKWB does not sell your Personal Data for money, we do share information for a various purposes, such as to tailor your online experience or provide more relevant advertisements to you.

CCPA identifies the categories below. This does not mean that all examples of that category of Personal Data were in fact "sold" but reflects our good faith belief to the best of our knowledge that some Personal Data may have been shared for value in return. We will update this disclosure from as appropriate.

A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers. Yes
B. Personal information categories listed in the California Customer Records statute(Cal. Civ. Code § 1798.80(e)) A 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. Some Personal Data included in this category may overlap with other categories. Yes
C. Protected classification characteristics under California or federal law 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). Yes
D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
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 patterns, and sleep, health, or exercise data. Yes
F. Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement Yes
G. Geolocation data Physical location or movements. Yes
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. Yes
I. Professional or employment-related information Current or past job history or performance evaluations. Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) 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. Yes
K. Inferences drawn from other Personal Data Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope.

We obtain the categories of Personal Data listed above from the following categories of sources:

  • Directly from our clients or their agents, such as from documents that our clients provide to us related to the Services or Products for which they purchase.
  • Indirectly from our clients or their agents, such as through information we collect from our clients in the course of providing Services to them.
  • Directly and indirectly from activity on our website (www.EKWB.com), such as from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the Services we perform.

Use of Personal Data

We may use or disclose the Personal Data we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided;
  • To provide you with information, Products, or Services that you request from us;
  • To provide you with email alerts and other notices concerning our Products or Services that may be of interest to you;
  • To improve our website and deliver its contents to you;
  • For testing, research, analysis and Product development;
  • As necessary or appropriate to protect the rights, property, or safety of us, our clients, 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 Personal Data or as set forth in the CCPA.

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

Sharing Personal Data

We may disclose your Personal Data to a third party for a business purpose. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside the United States, and may have different data protection laws than in the United States.

We disclose your Personal Data for a business purpose to the following categories of third parties:

  • Our affiliates;
  • Service providers; and
  • Third parties to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any Personal Data.

Your Rights and Choices

The CCPA provides consumers, who are California residents, with specific rights regarding their Personal Data.

Access to Specific Information and Data Portability Rights

You may request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Data we collected about you;
  • The categories of sources for the Personal Data we collected about you;
  • Our business or commercial purpose for collecting or selling that Personal Data;
  • The categories of third parties with whom we share that Personal Data;
  • The specific pieces of Personal Data we collected about you (also called a data portability request); and
  • If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Data categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Deletion Request Rights

You may request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Data from our records, unless an exception applies.

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

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 Data 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 Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, 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 to 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. 


We will not discriminate against you for exercising any of your CCPA rights. Unless the CCPA permits, we will not:

  • Deny you Products or Services.
  • Charge you different prices or rates for Products or Services.
  • Provide you a different level or quality of Products or Services.
  • Suggest that you may receive a different price or rate for Products or Services or a different level or quality of Products or Services.

Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our sole discretion. We will make any and all changes made privacy statement on our website.

Contact Information

If you have any questions or comments about this statement, our Privacy Notice, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights under California law, please email us at: [email protected].

To opt-out of the sale of your Personal Data, please click “Do Not Sell My Info” at the bottom of this page.