Last Updated:  October 1, 2023

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in Grace Hill, LLC’s Privacy Policy. (the “Privacy Policy”) It does not restate information already contained in the Privacy Policy, but incorporates by reference and in its entirety the Privacy Policy (and the Grace Hill Terms of Service, incorporated therein), which is hereby made an integral part of this Notice.

This Notice is pursuant to  the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020, and as to be effectuated by regulations thereunder promulgated by the California Privacy Protection Agency on March 29, 2023, to be effective on March 29, 2024, and, prior thereto, by regulations effective on August 14, 2020 as amended on March 15, 2021. Those statutes and regulations are referred to collectively herein as “CCPA.” Any terms defined in the CCPA have the same meaning when used in this Notice.  Capitalized Terms not defined in this Notice shall have the meanings ascribed to them in the CCPA or in the Privacy Policy.

This Notice applies to you if you are a natural persons who resides in the State of California ("consumers" or "you").

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; or
• Deidentified or aggregated consumer information.

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

 

Category	Types of information collected in this Category	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier or online identifier consisting of log-in credentials for the consumer’s Grace Hill account, Internet Protocol address, email address, Grace Hill account name.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, education, or employment.	YES
C. Protected classification characteristics under California or federal law.	Age and gender.	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
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.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with the Grace Hill website, a Grace Hill application (including KingsleySurvey), or a Grace Hill advertisement; but not about online activities over time and across third-party websites or online services.	YES
G. Geolocation data.	Physical location.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current job, and performance evaluations arising from a consumer’s interaction with training materials provided by Grace Hill.	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.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes arising from a consumer’s interaction with training materials provided by Grace Hill or with survey conducted by Kingsley.	YES

 

Sources From Which We Collect Personal Information

We obtain the categories of personal information listed above from the categories of sources identified in the Privacy Policy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the purposes identified in the Privacy Policy.

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 do reserve the right to use de-identified data for any legal purpose.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose as disclosed in the Privacy Policy.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

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

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our Clients.
• Service providers.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information.  

Your Rights and Choices

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

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 personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • 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.

Deletion Request Rights

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 and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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 or our Client.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 866-472-2344
• Emailing us at: [email protected]
• Visiting gracehill.com/privacy-policy-california/
• Accessing your Account and submitting a support request by entering a support ticket.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

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, which may include:
  • Sending a support request through your Account
  • Providing us with sufficient details about your Account for us to reasonably verify your identity
• 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. However, we do consider requests made through your Account sufficiently verified when the request relates to personal information associated with that specific Account.

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 will acknowledge receipt of your verifiable consumer request and describe the procedure for handling such a request within ten (10) days of receiving it. We will endeavor to respond to it within forty-five (45) days of its receipt. If we require more time (up to 90 days in total from receipt), we will within forty-five days 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, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will cover only 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.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell your personal information.  If, in the future, we begin selling personal information, we will amend this Notice to include information on opt-in and opt-out rights relating to such future sales of personal information. 

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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. In the event that we begin selling personal information, we will amend this Notice to include any financial incentives applicable to our use of your personal information.    

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: Grace Hill, 300 Executive Center Drive, Suite 201, Greenville, SC 29615. At this time, we do not disclose personal information to third parties for direct marketing purposes. If, in the future, we begin doing so, we will amend this Notice to disclose that.

Changes to Our Privacy 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 the Website and update the Notice's effective date. Upon the posting of any changed Notice, the changes from the previous version will be summarized at the top of the document. Your continued use of our Website and Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which Grace Hill collects and uses your information described here and in the Privacy Policy, or your choices and rights regarding such use, or if you wish to exercise your rights under California law, you may contact us at:

Phone: 866-472-2344

Website: gracehill.com/privacy-policy-california

Email: [email protected]

Postal Address:

Grace Hill

Attn: California Privacy Rights

300 Executive Center Drive, Suite 201

Greenville, SC 29615