This privacy statement (‘California Privacy Statement’) supplements the information contained in the Privacy Statement of HCL Software (‘HCL Software’ or ‘we’) and applies solely to visitors, users, and others who reside in the State of California (‘you’). We adopt this California Privacy Statement to comply with the California Consumer Privacy Act of 2018 (‘CCPA’), as amended by the California Privacy Rights Act of 2020 (‘CPRA’), and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this California Privacy Statement.
Your Rights Under the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This California Privacy Statement explains those rights.
Information We Collect
We collect information that relates to, is capable of being associated with, or could reasonably be linked to you or one of your devices (‘personal information’). In particular, we have collected the following categories of personal information within the last twelve (12) months:
Categories of Sources of Personal Information
We obtain the personal information listed above from the following categories of sources:
- You or your authorized parties or agents. Authorized parties or agents includes, but is not limited to, parties such as attorneys, guardians, and those with powers of attorney;
- Affiliates;
- Service providers;
- Our websites and mobile apps, or any time you visit, use, or interact with any of the features or services available on our mobile or online applications; and
- Data analytics providers.
Use of Personal Information
We collect, use, disclose or share the personal information for one or more of the following business or commercial purposes:
- To fulfill or meet the reason for which the information is provided;
- To provide you with information, products or services that you request from us;
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
- To improve our website and present its contents to you;
- For testing, research, analysis and product development;
- As necessary or appropriate to protect the rights, property or safety of us, yours or others;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosure of Personal Information
We may disclose your personal information to third parties for a business or commercial purpose. When we disclose personal information for a business or commercial 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.
We disclose your personal information for a business purpose to the following categories of third parties:
- Affiliates and subsidiaries;
- Internet service providers;
- Advertising networks;
- Data analytics providers;
- Service providers, which include nonaffiliated entities providing operating systems, platforms and other services to support day-to-day operations; and
- Government, regulatory, or legal authorities.
In the past twelve (12) months, we have disclosed the following categories of personal information for our business purposes:
- Identifiers;
- California Customer Records;
- Commercial information;
- Internet or other electronic network activity information; and
- Inferences drawn from other personal information.
Sharing and Sale of Personal Information
HCL Software does not “sell” or “share” your personal information within the meaning of the CCPA and we have not done so within the past 12 months. We only disclose your information as described in this policy and in the HCL Software Privacy Statement.
When you visit an HCL Software website, third party targeting cookies, if any, will only be present if that is in accordance with our Online Cookie Statement, and in line with your cookie choices that are presented to you on the website.
Your Rights and Choices
CCPA provides you with specific rights regarding your personal information. This section explains those rights.
Access to Specific Information and Data Portability: You have the right to request that we disclose certain information to you about our collection, use, disclosure, and/or sale of your personal information (if applicable) over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of personal information we have collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting, selling or sharing (if applicable) your personal information;
- The categories of third parties to whom we disclose your personal information;
- The categories of personal information that the business disclosed about you for a business purpose; and
- The specific pieces of personal information we collected about you (also known as right to ‘data portability’).
Correction or Deletion: You can request rectification (correction, updating or modification) or deletion of the personal information that HCL has collected from your use of our services. We will comply with your request as required by law, but this right does not apply where HCL needs to retain the personal information in order to provide goods or services to you, detect or resolve security issues or functionality-related issues, comply with the law, and carry out internal business requirements.
Opt-out: You have the right to opt out of advertisements that third parties may target to you. You can review the third-party advertising cookies and opt out of their use via the Cookie Preferences tool which is found on our webpage or in our Online Cookie Statement here. Please note that your opt-in/out selection through this tool applies to the browser and device you are using. If you access HCL website across multiple devices or browsers or if you clear your browser settings, you may have to make this selection again.
Should you choose to exercise any of your rights under the CCPA, HCL Software will not discriminate against you in any way. We will not charge you different prices for goods or services, whether through denying benefits or imposing penalties, provide you with a different level or quality of goods or services, or threaten you with any of the above actions.
How to Exercise Your Rights Under the CCPA
To exercise any of the rights described above, please submit a verifiable consumer request to us by either of the two options below:
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. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative).
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request if we cannot verify your identity 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 and/or authority to make the request.
We make an effort to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing, by mail or electronically, at your option. We will deliver our written response by email or through the Data Subject Request Portal.
You can designate an authorized agent to make a request under the CCPA on your behalf provided that (1) it is a natural person or a business entity registered with the Secretary of State of California; and (2) you have authorized the agent to act on your behalf.
Authorized agents may use the Data Subject Request Portal for further instructions. To protect your information, please note that we may take steps to verify your identity and we will also ask for a signed permission from you authorizing the authorized agent to submit a request on your behalf.
How Long Do We Retain Your Personal Information?
We retain your personal information for as long as it is necessary to fulfil the purposes for which it was collected, or longer if required to fulfil our legal and contractual obligations. After expiration of the retention period, your personal information will be deleted. If we are unable to completely delete the personal information from our systems, we will ensure that there are appropriate measures in place to secure the information and protect it from further use.
