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Privacy Statement - California

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Road America Motor Club and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to 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 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

  1. Accessibility. We are committed to providing everyone with access to this privacy notice and to our products and services.  If you have any difficulty reading this notice, you may call us toll free at 1.800.262.7262 so that we may assist you.
  2. Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months

    Category Examples of personal information Purposes
    A. Identifiers A real name, alias, postal address, unique personal identifier, online, identifier, alias, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, Unique Personal Identifier(s) and combinations, or other similar identifiers. To make contact with you when you are our customer or employee; conduct customer or employee needs assessments; improve the quality of products and services we deliver to customers and employees; inform you about our services, products and news when you visit our website or  subscribe to our newsletter or mailing lists; process employee payroll; administer and maintain employee benefits including health insurance, 401K and/or retirement plans; and effectively manage and support employees throughout the hiring, on-boarding, employment, and post-employment phases of their relationship with us, including to conduct background checks to ensure that employees satisfy company policies required to carry out their duties.
    B. Personal information categories listed in the California Customer Records statute  A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, prior claims and loss information. Some Personal information included in this category may overlap with other categories. To make contact with you when you are our customer or employee; conduct customer or employee needs assessments;  improve the quality of products and services we deliver to customers and employees; inform you about our services, products and news when you visit our website or subscribe to our newsletter or mailing lists;  process employee payroll; administer and maintain employee benefits including health insurance, 401K and/or retirement plans; and  effectively manage and support employees throughout the hiring, on-boarding, employment, and post-employment phases of their relationship with us, including to conduct background checks to ensure that employees satisfy company policies required to carry out their duties.
    C. Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). To the extent that we collect protected classification information, we collect such information to comply with federal and state law and/or, to deliver employee benefits & services.
    D. 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.  In certain circumstances, we may collect information to comply with federal and state requirements and/or, to deliver employee benefits & services including employee health insurance. 
    E. Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. We may collect such information to enhance marketing programs, and/or to determine consumer preferences.
    F. Geolocation data Physical location or movements We may collect such information in the course of providing services to you, to enhance our customer journey, and our client experience through Road America’s client console.
    G. Professional or employment-related information Current or past job history or performance evaluations. During the hiring process, we conduct background checks on prospective employees before finalizing an offer of employment.
    H. Non-public education information 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. During the hiring process, we conduct background checks on prospective employees before finalizing an offer of employment. Such background checks may include requesting Non-public education information.
    I. Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. During the hiring process of prospective employees, and periodically with current employees, we may conduct personality and/or leadership assessments.

  3. Information Sources. We obtain the categories of personal information listed above from the following categories of sources: (i) directly from you, our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us; (ii) indirectly from you, our clients or their agents. For example, through information we collect from our clients in the course of providing services to them; (iii) directly and indirectly from activity on our interactive dashboard tool, client console or website portal (www.road-america.com). For example, from digital dispatch/receive submissions through our interactive dashboard tool, client console or website portal or website usage details collected automatically; (iv) from third parties that interact with us in connection with the services we perform. For example, from clients and independent service providers when we arrange the dispatch of emergency roadside services.
  4. Sharing Personal Information. We may disclose your personal information to a third party for a business purpose. 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. 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 D: Biometric Information

    Category E: Internet or other similar network activity

    Category F: Geolocation data

    Category G: Professional or employment-related information

    Category H: Non-public education information 

    We disclose your personal information for a business purpose to the following categories of third parties: (i) our affiliates; (ii) service providers; and (iii) 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.

  5. Sale of Personal Information. We do not sell personal information to third parties.
  6. 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.

    (a) Right to Know: You have the right to know of the categories of personal information we collect, and the purposes for which the categories of personal information are used.  You also have a right to know of the categories of personal information that we have disclosed about you to another party for a business purpose.

    (b) 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, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information; and (v) the specific pieces of personal information we collected about you (also called a data portability request).

    (c) 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, 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 providers to: (i) 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, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.); (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; and (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    (d) Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    (e) Right to Opt-Out: The CCPA requires businesses that sell personal information to third parties to provide consumers with the right to opt-out of that business selling their personal information to third parties. We do not sell personal information to third parties.

  7. 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 phone at: 1.800.262.7262 or via e-mail at: ccparequest@road-america.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) 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 a verifiable consumer request to verify the requestor's identity or authority to make the request.
  8. Response Timing and Format. We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time, we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover 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.
  9. Other California Privacy Rights. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not sell personal information to third parties.
  10. Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
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