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CALIFORNIA CONSUMER PRIVACY ACT (CCPA) POLICY

This privacy policy and notice for California residents applies solely to visitors, users, and individuals, who reside in the State of California (“consumers,” “class members,” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). The terms “business,” “business purpose”, “personal information”, “processing”, and “service provider” have the meanings giving to them in the CCPA.

Our Role

Heffler Claims Group (“Heffler”) may collect and use consumer personal information for its commercial and business purposes and related operational purposes. With respect to these activities, Heffler may have direct responsibilities as a business subject to the CCPA. For example, with respect to certain activities related to direct interaction with consumers who have a direct relationship with Heffler, interacting with prospective/current clients, marketing, website and web application use, engaging vendors, and interacting with visitors/users of our Website. In these cases, this privacy policy is applicable.

Heffler also collects and uses personal information in its capacity as a Service Provider in order to perform our claims administration services on behalf of our clients and at the direction of the court. This means that throughout the claims administration process, the client retains control over personal information collected and processed. Where we collect and process your personal information on behalf of our clients to support claims administration, if you have questions or wish to exercise your rights relating to your personal information (such as information, access, or deletion) please contact that client directly.

Categories of Personal Information We Collect

The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual.

In the past 12 months, we have collected, used, and disclosed to third parties for our business purposes, the following categories of personal information relating to California residents covered by this policy:

Sources of personal information we collect:

• Information directly from you, the consumer or class member, that you choose to provide, when you interact with us, for example when you communicate with us by phone, email, or otherwise, submit a claim form, register for an event, subscribe to marketing or other communications, or inquire about, or purchase a product or service.
• Information we automatically collect when you interact with our website, content, or emails, such as your IP address and the pages you visited, and when you use our services, we may collect information on how you use those services. Please see our Cookie Policy for additional information.
• Information provided by our clients or the courts, in order for us to provide specific services as a Service Provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
• Information from Other Sources, including service providers or publicly available sources.

Business Purposes

We collect personal information to offer and administer our services and products

• To provide the products or perform services for clients pursuant to an agreement, including contacting you in the course of our ordinary commercial relationship, verifying client information, processing payments, or similar activities as needed to provide services for or on behalf of our clients.
• For marketing purposes. For example, we may use your information to further discuss your interest in the Services and to send you information regarding Heffler such as information about promotions, events, products or services. You may opt-out of receiving marketing communications and updates at any time.
• For improving Heffler’s communications with you. Emails sent to you by Heffler may include standard tracking, including open and click activities. Heffler may collect information about your activity as you interact with our email messages and related content, in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
• For operating and improving Heffler’s website and web applications and your customer experience, including debugging to identify and repair errors that impair existing intended functionality, or to verify or maintain the quality of our website, and to improve, upgrade, or enhance the website services. For example, we may collect and analyze data on your use of our website and process it for the purpose of improving our online experience. Please see our Cookie Policy for additional information.
• For security purposes, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• For other business purposes, which will be disclosed at the time we collect personal information.

Disclosure/Sharing of Personal Data

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

We share personal information for our business purposes with the following categories of third parties:

• Our clients and courts when necessary to complete the claims administration process.
• Our affiliates, as needed to operate our business and provide services.
• Service providers, such as vendors, consultants and other service providers who are performing certain services on behalf of Heffler, in which case we enter a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Your Rights

Subject to the CCPA and other applicable laws, you have the following rights concerning your data processed by Heffler:

• Access: You have the right to request to access the personal information that Heffler holds about you, including categories of information collected, categories of sources from which the information is collected, our business purpose for collecting information, and categories of third parties with whom we share your information.
• Deletion: You can request that Heffler erase your personal data.
• Non-discrimination: Heffler will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.

Please contact us if you wish to exercise your rights under CCPA:

• Via email: [email protected]
• In writing:
  Duff & Phelps Compliance and Privacy Office
  311 S. Wacker Drive, Suite 4200
  Chicago, IL 60605