CCPA Policy

California Privacy PolicY

EFFECTIVE DATE: January 1, 2020

UPDATED: August 19, 2020 


This Privacy Policy provides California residents with specific information about AIS and its affiliated companies’ collection and use of their personal information. This Policy also is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”), with respect to the personal information we collect about you.

What is personal information? In this Privacy Policy, “personal information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

What isn’t covered by this policy? This Privacy Policy does not address or apply to our collection of personal information, such as protected health information (or “PHI”), consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, or other information that is exempt under the CCPA. Except for the Right to Opt-out and the Right of Non-Discrimination, this Privacy Policy does not apply to California residents with whom we transact or communicate solely in the context of providing or receiving a product or service to or from a company that employs such residents or engages such residents as contractors. This section also does not apply to personal information we collect about job applicants, independent contractors, or current or former full-time, part-time and temporary employees and staff, officers, directors or owners of AIS (“AIS”).

Categories of Personal Information that We Collect and Disclose

Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and the nature of our interactions or relationship with such resident. We collect your personal information from our business partners, credit bureaus, bankruptcy courts, probate courts and data brokers to provide financial and legal services to our commercial clients and for quality control and assurance purposes. The table below sets out the general categories of personal information (as defined by the CCPA) about California residents that we collect and disclose to others for a business purpose.

Categories of personal information Do we collect? Do we disclose for a business purpose(s) Do we sell?
Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, or other similar identifiers. YES YES NO
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, current employment, employment history, social security 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 or payment information, medical information, or health insurance information. YES YES NO
Protected Classifications: Characteristics of protected classifications under California or federal law such as sex and age YES YES NO
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, including access logs and other activity information related to your use of any AIS websites, applications or other online services. YES NO NO
Geolocation Data: Precise geographic location information about a particular individual or device. YES YES NO
Audio, Video and other Electronic Data: Audio, electronic, or similar information such as call recordings. YES YES NO

California Resident Rights

California law grants California residents certain rights and imposes restrictions on particular business practices. This section describes your CCPA rights and explains how to exercise those rights.

Do-Not-Sell. California residents have the right to opt-out of the sale of their personal information. AIS does not offer the opt-out from the sale of personal information because AIS does not engage in the sale of personal information as contemplated by the CCPA.

Initial Notice. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies.

Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

  • categories of personal information collected;
  • categories of sources of personal information;
  • business and/or commercial purposes for collecting and selling their personal information;
  • categories of third parties with whom we have disclosed or shared their personal information;
  • categories of personal information that we have disclosed or shared with a third party for a business purpose; and
  • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make a Request to Know up to twice every 12 months.

Submitting Requests. Under the CCPA, California residents have the right to submit A Request to Know, Request to Delete, or Request to Opt-Out of the Sale of their Personal Information. However, the CCPA also requires that we reasonably verify each Request to Know or Request to Delete before responding.

You may submit CCPA consumer requests by clicking here to complete the online form or by emailing us at [email protected]. We will respond to verifiable requests received from California residents as required by law.

Right to Non-Discrimination. The CCPA prohibits “discrimination” against California residents for exercising their rights under the CCPA. The CCPA definition of Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

Financial Incentives. A business may offer financial incentives for the collection, sale, or deletion of California residents’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any incentives at this time.

Changes to this Policy

This notice will be changed from time to time. If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

Contact Us

For more information about our privacy practices, please contact us: [email protected]