California Consumer Privacy Notice
This PRIVACY NOTICE FOR CALIFORNIA CONSUMERS supplements the information contained in the Privacy Policy of Hughes Marino, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to consumers who reside in the State of California (“you”). This serves as our Notice at Collection. We may also provide additional Privacy Notices to you based on your interactions with us. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
The personal information we collect or otherwise receive depends on the nature of your relationship to Hughes Marino. We collect the information described below 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 |
|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | 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 (including descriptions concerning health symptoms, test results, and vaccination status), or health insurance information. Some personal information included in this category may overlap with other categories. |
| 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). |
| D. Commercial Information | Records of your personal property, products or services purchased, or other consuming histories or tendencies. |
| E. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. |
| F. Geolocation data | Physical location or movements. |
| G. Professional or Employment Related Information | Your current or past professional history. |
| H. Inferences drawn from Personal Information | Your attitudes and abilities. |
| I. Sensitive Personal Information | A social security, driver’s license, state ID, or passport number; financial account information; and racial or ethnic origin. |
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you and your interactions with us. For example, you may visit our website, fill out the “contact us” form, or you may have contact with our offices or representatives.
- Online activity information that is collected by us and third parties through the use of cookies on the website.
Use of Personal Information
The way we use or disclose personal information will depend on the context of your interactions with us and the particular business services Hughes Marino is performing. We may use or disclose the personal information we collect for one or more of the following business purposes:
- To perform services on behalf of Hughes Marino. For example, contacting and meeting with our clients, managing client relationships, marketing communications, and analytic activities.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for any materially different, unrelated, or incompatible purposes without providing you notice. We do not collect sensitive personal information with the purpose of inferring characteristics about a consumer.
Retainment Policy
How long we keep Personal Information can differ depending on the purpose of collection and your relationship with the company. Generally, once a relationship ends we will retain the Personal Information for a short period before evaluating if the information needs to be retained.
We consider factors such as our legal and regulatory obligations as well as whether the data is needed for internal business purposes when determining how long data is retained. We may also retain Personal Information if it is determined to be necessary due to:
- a California or Federal regulatory compliance requirement; or
- exercising, establishing, or defending legal claims.
Sharing Personal Information
We may disclose your personal information to provide our services.
In the preceding twelve (12) months, we have disclosed the following categories of personal information, as described above in Information We Collect, to perform services on behalf of the business:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or Federal law.
Category D: Commercial Information.
Category E: Internet or other similar network activity.
Category F: Geolocation data.
Category G: Professional or Employment Related Information
Category H: Inferences drawn from Personal Information
Category I: Sensitive Personal Information.
We disclose your personal information for a business purpose to the following parties:
- our affiliates;
- service providers, contractors, and their agents;
- financial service providers;
- third party vendors;
- other parties (including government agencies) as required by law; and
- other parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you
Categories E and F may be shared with third party vendors during your interaction with hughesmarino.com through the cookies present on the website.
Our website currently utilizes cookies to perform strictly necessary functions, as well as improve website performance. There are also targeting cookies present on our website. Strictly necessary cookies are used to distinguish between human and bot website visitors. Performance cookies assist us in curating the performance of our website, we use them to collect information such as unique users, page visits, and session data. Targeting cookies may provide us with information about what advertising has been viewed prior to coming to our website and general geographic location of browsers and target ads.
You can control our use of cookies and sharing activities on the website through the opt-out banner at the bottom of this page or you can contact us via the contact information below. If you have already interacted with the opt-out banner and you would like to review or change your choices, you can access the banner by clicking on the circle icon at the bottom left of the page.
When we disclose personal information, including sensitive personal information, for a business purpose, we enter a contract with our service providers and contractors 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 not sold personal information as defined by California Civil Code § 1798.140.
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 by email or through a notice posted on our website homepage: https://hughesmarino.com/hughes-marino-data-privacy-policy/.
Contact Information
If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, please do not hesitate to contact us at:
| Phone: | 1-833-389-0117 |
|---|---|
| Email: | Privacy@HughesMarino.com |
| Address: | Hughes Marino Attn: Legal Department 1450 Front Street San Diego, CA 92101 |
