California Consumer Privacy Act Disclosures
In these California Consumer Privacy Act Disclosures (“CCPA Disclosures”), Topco Associates, LLC (“Topco”) disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”), and supplement the disclosures in any CCPA Notice at Collection issued in addition to the CCPA Notice at Collection Online provided in Section III below. These CCPA Disclosures are effective as of 11/1/2020.
I. Who and what information is subject to these CCPA Disclosures?
California residents are protected as “consumers” by the CCPA with respect to personal information. A number of statutory exceptions apply under the CCPA and to these CCPA Disclosures, including the following:
- personal information reflecting a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency.
- personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business.
- personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file.
- personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. How can a consumer with a disability access these CCPA Disclosures?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.
III. CCPA Notice at Collection
Pursuant to California Civil Code §1798.100(b) and California Attorney General Regulations § 999.305, Topco makes this disclosure at or before the point of collection. Topco collects the categories of personal information about consumers for the business and commercial purposes set out in our CCPA Privacy Policy, which is set forth below.
Topco provides the linked disclosures about consumer rights and personal information handling practices in the preceding twelve months, as required by the CCPA and Section 999.308 of the California Attorney General regulations (Privacy Policy).
