This section applies to Personal Information that is not covered by the GLBA or other applicable law for residents of California. This California Privacy Notice (“CA Notice”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) and describes how Oswald processes Personal Information of California consumers. This CA Notice supplements our other privacy policies and notices, including our main Privacy Notice above.

In the event of a conflict between any other policy, statement, or notice and this CA Notice, this CA Notice will prevail as to California residents.

Unless otherwise noted, the disclosures that describe how and why we collect, use, and disclose your Personal Information also describe how and why we collected, used, and disclosed your Personal Information within the past twelve (12) months.

Your Privacy Rights

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. You have the following rights:

• Know: You have the right to know what Personal Information that we hold about you, upon receipt of a verified request, which includes:
  • the categories of Personal Information we collected about you;
  • the specific pieces of Personal Information we collected about you;
  • our business or commercial purposes for collecting, selling, sharing, or disclosing Personal Information;
  • the categories of recipients to which we disclose Personal Information;
  • the categories of sources from which we collected Personal Information ;
  • the categories of Personal Information that we sold or shared and, for each identified category, the third persons with whom we sold or shared Personal Information;
  • the categories of Personal Information that we disclosed for a business purpose, and for each identified category, the categories of recipients to which we disclosed Personal Information.
• Accuracy: You have the right to request that we correct any inaccurate or out of date Personal Information.
• Deletion: You have the right to request that we delete your Personal Information, with some exceptions.
• Non-Discrimination: You have the right to equal treatment regardless of your exercise of your privacy rights.
• Sensitive Personal Information: You have the right to direct us to limit, with some exceptions, our use and disclosure of your Sensitive Personal Information, as defined below, to uses or disclosures of your Sensitive Personal Information to those uses or disclosures that are reasonable necessary to provide our goods and services, or as needed to perform certain other services.
• Opt Out: You have the right to opt out of the sale of your Personal Information and the sharing of your Personal Information for cross-context behavioral advertising.  We do not presently sell, use for profiling, or share Personal Information for targeted or cross-context behavioral advertising.

You, or a person authorized by you under the laws of your state to act on your behalf, may request the following information or exercise any of the above rights by writing to Privacy Management, c/o Compliance Officer, Unison Risk Advisors; 1100 Superior Ave, Suite 1500, Cleveland, Ohio 44114, via email to [email protected], or by calling 1.855.467.9253.

We may provide this information in a standardized format that is not entirely specific to you.  Before we may fulfill a request to access, correct, limit the use of, or delete your information, we may be required to verify your identity.  If you submit a request to know, request to delete, or request to correct, we will ask you to verify your identity, which may include your name, address, date of birth, and government-issued identification number. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.

Personal Information We Collect and Why We Collect It

We share the following categories of Personal Information from the sources and for the purposes listed above. We collect the following categories of Personal Information from our California consumers. The Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

Category/Examples	Collected
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.	Yes
Identifiers such as social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal information categories listed in the California Customer Records statute §1798.80(e) such as a name, address, education, employment, and employment history. Some personal information included in this category may overlap with other categories.	Yes
Personal information categories listed in the California Customer Records statute §1798.80(e) such as Signature, Social Security number, physical characteristics or description, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	Yes
Characteristics of protected classifications under California or federal law such as age or gender.	Yes
Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
Internet or other electronic network activity information such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Audio, electronic, visual, thermal, olfactory or similar information such as call recordings, chat transcripts, email correspondence, testimonials, pictures, diagrams of your properties and equipment (including satellite imagery).	Yes
Professional or employment-related information such as current or past job history or performance evaluations.	Yes
Inferences drawn from other Personal Information such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Yes
Sensitive Personal Information such as identification numbers (like Social Security number), financial account and access information, personal demographic information (like your race, religion, philosophical beliefs), genetic or biometric information, and information about your health or sexual activity.	Yes

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

How Long We Keep Your Personal Information

For each category of information, our retention period is determined by the purposes for which we use the information and any legal obligations that require or authorize us to retain it.

How We Sell and Share Personal Information

We do not, and within the past twelve (12) months, have not, sold or shared for cross-context behavioral advertising the Personal Information of California consumers.

Disclosures for a Business or Commercial Purpose

We may disclose and, during the last twelve (12) months, have disclosed the above categories of Personal Information to our service providers and contractors for the following business purpose:  

• Ensuring security and integrity of Personal Information
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use
• Performing services on our behalf
• Providing advertising and marketing services (except for cross-context behavioral advertising)
• 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 us
• Processing, maintaining, or collecting Personal Information on our behalf
• Detecting or protecting against malicious, deceptive, fraudulent or illegal activity
• For internal use by the service provider
• To communicate with third parties in possession of Personal Information when you exercise a right (e.g. Right of Deletion Request)

Revision date: 5/1/2023