CALIFORNIA PRIVACY POLICY

Last Updated: April 18, 2024

CDLMatch.com (also referred to herein as the "Company") takes your privacy seriously. We want you to know how we collect, use, share, and protect your Personal Information and about the rights of California Consumers under California law.

This Privacy Policy addresses the following topics

• The Scope of this Privacy Policy
• Collection, Use and Disclosure of Personal Information
• Your California Privacy Rights
• How to Exercise Your Rights
• How We Will Verify Your Requests
• Requests by Authorized Agents
• Non-Discrimination Policy
• Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes
• Your "Do Not Track" Browser Setting
• Third-Party Links and Services
• Minors Under 16 Years of Age
• For More Information
• Changes to This California Privacy Policy

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at security@cdlmatch.com for assistance.

The Scope Of This Privacy Policy

What Is Personal Information?

"Personal Information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.

Whose Personal Information Is Covered By This Policy?

This California Privacy Policy applies to the Personal Information of residents of the State of California in their capacity as consumers ("California Consumers").

What Personal Information Does This Privacy Policy Cover?

This Privacy Policy applies to all Personal Information of California Consumers that we collect both online and offline, including through California Consumers' visits to our website, www.cdlmatch.com, and personal information that you submit (whether in person, over the phone, in writing, or otherwise) or that we collect via online fillable forms, email or SMS campaigns, mobile applications, software, or any other CDLMatch.com product or service that incorporates this Privacy Policy by reference (collectively, the "Services").

What Else Should I Know About CDLMatch.com's Handling Of California Consumers' Personal Information?

Please read CDLMatch.com's general Privacy Policy available at https://cdlmatch.com/privacy-policy/ carefully, as it contains important information about your use of the Services. If you have any questions, please contact us using the information below.

Collection, Use And Disclosure Of Personal Information

This section of the Privacy Policy describes, for the 12 months preceding the date last updated, above, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information. Unless we inform you otherwise, this section also serves as our "notice at collection" by informing you of your Personal Information to be collected in the future and the purposes for its use.

Categories Of Personal Information Collected

In the last 12 months, CDLMatch.com collected the following categories of Personal Information about California Consumers:

• Identifiers, including: real name, postal address, phone number, fax number, unique personal identifier, online identifier, Internet Protocol address, email address, and user name and password for your account.
• Characteristics of protected classifications under California or federal law, including: race and gender, age and veteran status (age and veteran status information if submitting an online pre-qualification form).
• Internet or other electronic network activity information, including: browsing history, search history, and information regarding your interaction with our website, application, or advertisement.
• Sensory information, including: recorded recruiting calls.
• Professional or Employment-Related Information, including: preferred language, your organization, and license type information.
• Profile information, including: information entered, in narrative form, into request forms, surveys, and live recruiting chats; inquiries or other communications submitted by email.

Sources Of Personal Information and Purposes For Using Personal Information

In the last 12 months, CDLMatch.com collected the categories of Personal Information listed above from the following sources and used those categories of Personal Information for the following purposes:

Categories of Personal Information Collected in the Last 12 Months	Sources of that Personal Information	Business Purposes and Commercial Purposes for Collecting that Personal Information
Identifiers	From the California Consumer	Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with the law. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing intended functionality. Short-term, transient use. Performing services, including maintaining or servicing accounts, providing recruiting services, verifying lead information, providing advertising or marketing services, and providing analytic services. Undertaking internal research for technological development and demonstration. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Company. Product and service training, for example, by providing training and information on using, servicing, selling, and displaying Company's products and services. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers and prospective employees or contractors, including regarding questions and feedback.
Characteristics of protected classifications under California or federal law	From the California Consumer when he or she is submitting an online pre-qualification form	The purposes listed for "Identifiers," EXCEPT for: Debugging to identify and repair errors that impair existing intended functionality. Undertaking internal research for technological development and demonstration. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Company. Product and service training, for example, by providing training and information on using, servicing, selling, and displaying Company's products and services. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys.
Internet or other electronic network activity information	Automated technologies in the website, including cookies, Google Analytics, device identification	The purposes listed for "Identifiers," EXCEPT for: Debugging to identify and repair errors that impair existing intended functionality. Short-term, transient use. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback.
Sensory information	From the California Consumer	The purposes listed for "Identifiers," EXCEPT for: Debugging to identify and repair errors that impair existing intended functionality. Undertaking internal research for technological development and demonstration. Undertaking internal research for technological development and demonstration. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Company. Product and service training, for example, by providing training and information on using, servicing, selling, and displaying Company's products and services. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys. In addition: Communications about employment or contracting opportunities.
Professional or employment-related information	From the California Consumer	The purposes listed for "Identifiers," EXCEPT for: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing intended functionality. Undertaking internal research for technological development and demonstration. Communications about promotions, for example, by communicating about special events, sweepstakes, promotions and surveys. Facilitating communications, for example, by collecting and organizing contact information, establishing means of communications, and communicating with current and prospective customers, including regarding questions and feedback. In addition: Communications about employment or contracting opportunities.
Profile information	From the California Consumer	The purposes listed for "Identifiers," EXCEPT for: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. Debugging to identify and repair errors that impair existing intended functionality. In addition: Communications about employment or contracting opportunities.

Disclosure Of Personal Information To Third Parties

In the last 12 months, CDLMatch.com disclosed the following categories of Personal Information about California Consumers to the following categories of third parties for a business or commercial purpose:

Category of Personal Information	Categories of Third Parties
Identifiers	Service Providers including providers of Data Collection Technologies, providers of data analytics services, website providers, and e-commerce vendors Government agencies, law enforcement, and other parties as required by law, including in litigation Outsourced recruiting services providers
Characteristics of protected classifications under California or federal law	Government agencies, law enforcement, and other parties as required by law, including in litigation
Internet or Other Electronic Network Activity Information	Service Providers, including providers of Data Collection Technologies, providers of data analytics services, and website providers
Sensory Information	Government agencies, law enforcement, and other parties as required by law, including in litigation
Professional Or Employment-Related Information	Service Providers, including providers of Data Collection Technologies, providers of data analytics services, and website provider Government agencies, law enforcement, and other parties as required by law, including in litigation
Profile Information	Outsourced recruiting services providers

Notice of Sale or Sharing of Personal Information

CDLMatch.com may “share”, i.e., disclose to a third-party for cross-context behavioral advertising, the Personal Information of California Consumers who provide their information to CDLMatch.com. This information is shared to provide targeted advertisements to Consumers who express interest in the services the Company offers. The third party’s use of your Personal Information is limited to this purpose and will not be further shared or sold to other entities, but it may be disclosed to contractors to satisfy this limited purpose.

In the last 12 months, CDLMatch.com shared the following categories of Personal information about California Consumers to the following categories of third parties:

Category of Personal Information	Categories of Third Parties
Identifiers	Service Providers, including providers of data collection technologies, providers of data analytics services, website providers, marketing services providers, and e-commerce vendors.

CDLMatch.com will not sell or share your Personal Information to third parties for any uses outside of the limited purpose described above. If you would like to opt out of the sale or sharing of your information, please fill out this form or email security@cdlmatch.com.

Note on Sensitive Personal Information: CDLMatch.com does not infer characteristics from sensitive personal information. CDLMatch.com may use sensitive personal information only as reasonably necessary and proportionate for the following purposes:

• to perform the services or provide the goods reasonably expected by an average Consumer who requests those goods or services.
• to prevent, detect, and investigate security incidents involving personal information
• to resist malicious, deceptive, fraudulent, or illegal actions directed at CDLMatch.com and to prosecute those responsible for those actions
• to ensure the physical safety of natural persons
• for short-term, transient use
• to maintain the quality or safety of CDLMatch.com’s services
• to improve, upgrade, or enhance CDLMatch.com’s services
• other purposes that do not infer characteristics about California Consumers

Consequently, the right to restrict the use or disclosure of sensitive personal information under the California Privacy Rights Act (“CPRA”) does not apply.

Your California Privacy Rights

Right to Know

California Consumers have the right to submit a verifiable request to know:

• The categories and specific pieces of Personal Information that CDLMatch.com has collected about them;
• The categories of sources from which CDLMatch.com collected the Personal Information;
• The categories of Personal Information that CDLMatch.com sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
• The business or commercial purposes for CDLMatch.com's collection, disclosure, or sale of the Personal Information.

Right To Delete

• California Consumers have the right to submit a verifiable request for deletion of their Personal Information that CDLMatch.com has collected from the Consumer.

Right to Opt Out of Sale of Personal Information

• California Consumers have a right to opt-out of the sale of the Personal Information. If you would like to opt out of the sale or sharing of your information, please fill out this form or email security@cdlmatch.com

Right to Correct

• California Consumers have the right to submit a verifiable request to correct inaccurate Personal Information maintained by CDLMatch.com or on its behalf, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.

How to Exercise Your Rights

CDLMatch.com will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:

• Complete the online request form available here.
• Contact by telephone: 1-855-785-7362.
• If you would like to opt out of the sale or sharing of your information, please fill out this form or email security@cdlmatch.com

Requests By Authorized Agents

You may designate an authorized agent to exercise your right to know or your right to delete by submitting to us a completed "Authorized Agent Designation" form. You can obtain the designation form by contacting us at security@cdlmatch.com.

If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described herein for verifying your identity.

How We Will Verify Your Requests

The processes that we follow to verify that the person making a request to know or a request to delete is the person about whom we have collected personal information are described below. The relevant process depends on how and why the request is submitted.

Requests Through Your Password-Protected Account

If you created a password-protected account with us before the date of your request, we will rely on the fact that your request has been submitted through your account as verification of your identity. We will require that you re-authenticate yourself before we disclose your personal information in response to a request to know and before we delete your personal information in response to a request to delete.

You are responsible for protecting the security of your log-in credentials for your account. Please do not share your log-in credentials with anyone. If we suspect fraudulent or malicious activity on or from your account, we will not respond to a request to know or a request to delete until we have been able to confirm, through further verification procedures, that you made the request.

Requests Other Than Through A Password-Protected Account

If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:

• Requests To Know Categories Of Personal Information: We will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or information about services that you have received from us.
• Requests To Know Specific Pieces Of Personal Information: We will match at least three data points that you provide with your request to know, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity.
• Requests To Delete Personal Information: Our process for verifying your identity will depend on the sensitivity (as determined by CDLMatch.com) of the personal information that you ask us to delete. For less sensitive personal information, we will require a match of two data points as described in Point No. 1, above. For more sensitive personal information, we will require a match of three data points as described in Point No. 2, above.

We have implemented the following additional procedures when verifying the identity of requestors:

1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification.
2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

Requests to Opt Out of the Sale or Sharing of Personal Information

Once you have provided the requested information in the online form, your information will be removed from the data set provided to third parties. The third parties will also be notified of your request and directed to remove your information from their distribution lists. This type of request only applies to the sale or sharing of your Personal Information. CDLMatch.com will securely maintain your Personal Information and may use it for purposes that do not involve the sale or sharing of your Personal Information, in accordance with the CDLMatch.com’s Privacy Policy.

Non-Discrimination Policy

California Consumers have the right not to be subject to discriminatory treatment by CDLMatch.com for exercising their privacy rights under the California Consumer Privacy Act, and CDLMatch.com will not discriminate on that basis. However, CDLMatch.com may provide a California Consumer a different level or quality of services if the difference is reasonably related to the value provided to the California Consumer by the Consumer's Personal Information. If Company does so, it will provide Consumers with any legally required notice.

Your Right to Information About Disclosures of Personal Information for Direct Marketing Purposes:

Under California law, California Consumers can request information from us whether we have disclosed Personal Information to any third parties for the third parties' direct marketing purposes. We will not sell your Personal Information to, or share it with, third-party companies for their direct marketing purposes without your consent. California Consumers desiring to request further information about our compliance with these laws or who have questions or concerns about our privacy practices and policies are welcome to contact us using the contact information below.

Your 'Do Not Track' Browser Setting

The Site collects personally identifiable information about your online activities over time and across third-party websites or online services. Please see our online Privacy Policy at https://cdlmatch.com/privacy-policy/ for additional information.

Third-Party Links And Services

We provide links to third party websites operated by organizations not affiliated with CDLMatch.com. We do not disclose your Personal Information to organizations operating such linked third-party websites. We do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each and every website that you visit. This Privacy Policy applies solely to information collected by CDLMatch.com through the Services.

Minors Under 16 Years of Age

We respect the privacy of children. Our Services are not designed to attract an audience younger than sixteen (16), and we do not knowingly collect Personal Information from children under sixteen (16). If you are under the age of sixteen (16), you are not permitted to use our Services and should not send any information about yourself to us through the Services. Please contact us using the contact details below if you believe we may have collected information from your child under the age of sixteen (16), and we will work to delete it.

For More Information

For questions or concerns about CDLMatch.com's privacy policies and practices, please contact us at security@cdlmatch.com.