Privacy Policy

13. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. To learn more about California residents' privacy rights, visit CALIFORNIA CONSUMER PRIVACY ACT

This Privacy Policy for California Residents supplements the information contained in the Woods Oviatt Gilman LLP Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

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.

Right to Know and Data Portability

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 (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Correct 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 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, we will provide information about the disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
• The specific pieces of Personal Data We collected about You (also called a data portability request).

Right to Correct

You can review and request a change to your Personal Information. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete, or Correct), we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

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 (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Correct 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:

1. Fulfill our obligations to provide our legal services, enforce our contractual rights, fulfill our obligations under the Rules of Professional Responsibility, and maintain records of the legal services rendered and amounts paid.
2. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
3. Comply with a legal obligation.
4. 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.

Exercising Your Rights to Know, Correct or Delete

To exercise your rights to know, correct, or delete described above, please submit a request by either:

• Calling us at 800-333-2414.
• Emailing us at privacy@woodsoviatt.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• 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.

We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@woodsoviatt.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

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.

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 services.
• Charge you different prices or rates for 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.