These disclosures are provided by Partners in Leadership, LLC, a California limited liability corporation doing business as Culture Partners (“Company”) and applies solely to residents of the State of California (“consumers” or “you”) with respect to personal information Company processes as a business. Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations (“CCPA”) have the same meaning when used in these disclosures. These disclosures do not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception or exemption under the CCPA applies. You can download a pdf version of these disclosures.
1. Notices at Collection
We have set out below categories of personal information about California resident website visitors, customers, prospective customers, corporate representatives of our vendors and other partners, and job applicants and other potential employees. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.
Website Visitors:
What Categories of Personal Information Do We Collect?
Non-Sensitive Personal Information:
Sensitive Personal Information:
For What Purposes Do We Collect and Use Personal Information?
We use personal information about our website visitors as reasonably necessary and proportionate to:
We do not sell or share for personal information of California residents, and we do not respond to Do Not Track signals. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.
To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/.
You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
What Criteria Do We Consider When Retaining Personal Information?
In general, with respect to each category of personal and sensitive personal information about website visitors, we retain each category for the longer of: as long as needed or permitted in light of the purpose(s) for which it was obtained and any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up and deletion processes.
Job applicants or Other Potential Workers:
What Categories of Personal Information Do We Collect?
Non-Sensitive Personal Information:
Sensitive Personal Information:
For What Purposes Do We Collect and Use Personal Information?
We use personal and sensitive personal information about you as a job applicant or other potential worker for the following purposes as reasonably necessary and proportionate to:
We do not sell or share any personal information of California residents. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.
What Criteria Do We Consider When Retaining Personal Information?
In general, with respect to categories of personal and sensitive personal information about job applicants and other potential workers, we retain each category for the longer of: until the withdrawal or rejection of your application, or if you are engaged, until the end of your engagement or employment, plus 4 years and any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up and deletion processes.
Customers Including Course Registrants, Prospective Customers, Corporate Representatives of Our Vendors and Other Partners:
What Categories of Personal Information Do We Collect?
Non-Sensitive Personal Information:
For What Purposes Do We Collect and Use Personal Information?
We use personal information about you as a customer, prospective customer, corporate representative of our vendors and other partners as reasonably necessary and proportionate for the purposes of:
We do not sell or share personal information of California residents and we do not respond to Do Not Track signals. The California Consumer Privacy Act Privacy Policy is in Section 2 of these disclosures.
What Criteria Do We Consider When Retaining Personal Information?
In general, with respect to categories of personal information about customers, prospective customers, corporate representatives of our vendors and other partners, we retain each category for the longer of: a.) until we determine that the Company will not be engaged by or engage the customer, vendor, or partner, or if a customer, vendor or partner engages or is engaged by the Company, until the end of such engagement, and b. any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up and deletion processes.
2. California Consumer Privacy Act Privacy Policy
Last Updated: October 2, 2024
Our Personal Information Handling Practices in 2023
In the CCPA Table below, we have set forth categories of personal information about California residents we have collected, and as applicable disclosed, for a business purpose in the preceding 12 months. The table is followed by a description of the purposes for which we collected personal information. In the preceding 12 months we did not sell or share the personal information of California residents. If we process de-identified information, we will maintain the information in a deidentified form and not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether deidentification processes used satisfy legal requirements.
Category of Personal Information: |
From what source did we collect? |
Did we disclose? If so, to whom and for what purpose? |
Non-Sensitive Personal Information |
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Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
From website visitors, job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her 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, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. |
From website visitors, job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
(The categories of personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) |
From job applicants and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Characteristics of protected classifications under California or federal law. |
From job applicants and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Commercial information, including records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
From website visitors, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. |
From website visitors, job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Geolocation data. |
From website visitors, job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
From job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Professional or Employment related information. |
From job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). |
From job applicants and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
From website visitors, job applicants, customers including course registrants, prospective customers, corporate representatives of our vendors and other partners, and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
Sensitive Personal Information |
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A consumer’s social security, driver’s license, state identification card, or passport number, citizenship or immigration status |
From job applicants and employees. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. |
From website visitors. |
Yes, to employees and third-party service providers. We disclose this information to receive services, to facilitate corporate transactions, and to comply with the law. |
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. |
From employees. |
Third party service providers and to comply with the law. |
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. |
From employees. |
Third party service providers and to comply with the law. |
A consumer’s precise geolocation. |
From job applicants and employees. |
Third party service providers and to comply with the law. |
Personal information collected and analyzed concerning a consumer’s health. |
From employees. |
Third party service providers and to comply with the law. |
Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. |
From employees. |
Third party service providers and to comply with the law. |
Business or Commercial Purpose for Collecting Personal Information
We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age.
Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please email legal@culturepartners.com or call 1-800-504-6070.
Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.
Authorized Agents: You can designate an authorized agent to make a request under the CCPA on your behalf if:
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Contact Us
If you have any questions or comments about these disclosures or our practices, please contact us at:
Email address: legal@culturepartners.com
Postal address: 27555 Ynez Road, Suite 200, Temecula, CA 92591