Effective Date – January 1, 2024

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Gelfand, Rennert & Feldman, LLC (“we,” “our,” “us”) and applies to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other California privacy laws.

Information We Collect

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated. We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

We also collect some Personal Information that does not directly fit within one of the categories defined by the CCPA. For example, we collect visa information, your mother’s maiden name, and the contents of communications you send to us. Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Commercial Information.

Sensitive Personal Information

Within the past twelve (12) months, we collected, used, and disclosed the categories of Sensitive Personal Information about California consumers that are indicated in the chart below. Note that the Sensitive Personal Information we collect may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

Category of Sensitive Personal Information	Categories of Sources from which Information was Collected	Purposes for Collection / Use / Disclosure	Categories of Recipients to which Information was Disclosed
Personal Information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number.	• Directly from you or from your representative. • From third parties that interact with us in connection with the services we perform.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Personal Information that reveals 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.	• Directly from you or from your representative. • From third parties that interact with us in connection with the services we perform.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.	• Directly from you or from your representative.	• To provide you with information, products or services that you request from us.	• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Contents of mail, email, and text messages except those for which we are the intended recipient	• Directly from you or from your representative.	• To provide you with information, products or services that you request from us.	• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
Personal Information collected and analyzed concerning a consumer’s health.	• Directly from you or from your representative.	• To provide you with information, products or services that you request from us.	• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

The Right to Limit Use

• 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

We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply: 

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;  
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; 
• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or 
• We are otherwise required or permitted to keep your information by applicable laws or regulations. 

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

Disclosures of Personal Information

Within the preceding twelve (12) months, we have not sold or shared for cross-context behavioral advertising the Personal Information of California consumers. We may disclose your Personal Information for a business purpose. When we disclose Personal Information for a business 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.

Disclosures for a Business or Commercial Purpose

The chart below shows the categories of Personal Information we have disclosed to our service providers and contractors for a business or commercial purpose during the last twelve (12) months.

Category of Personal Information or Sensitive Personal Information		Categories of Recipients to which Information was Disclosed	Purposes for Disclosure
Personal Information
	Identifiers	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.
	Personal Information described in Cal. Civ. Code § 1798.80(e)	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.
	Characteristics of protected classifications	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.
	Commercial information	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.
	Professional or employment-related information	• Our affiliates. • Service providers. • Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.	• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities. • To provide you with information, products or services that you request from us.

Your Rights and Choices

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our intake form or call us at (833) 479-0336. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to verify your identity in accordance with the law. 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. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

• Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

(1) The categories of Personal Information we have collected about you, including:

1. The categories of sources from which the Personal Information was collected.
2. Our business or commercial purposes for collecting or disclosing Personal Information.
3. The categories of recipients to which we disclose Personal Information.
4. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

(2) The specific pieces of Personal Information we have collected about you.

• Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.
• Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
• Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

Third-Party Marketing

We do not share Personal Information as defined by California Civil Code § 1798.83 (“Shine the Light” law) with third parties for their own direct marketing purposes.

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 you by email or through a notice on our website homepage.

This Privacy Notice can be found online at https://www.grfllp.com/privacy-policy-california/

Contact Information

If you have any questions or comments about this notice, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (833) 479-0336

Website: www.grfllp.com

Postal Address:

Privacy and Information Security Office
Gelfand, Rennert & Feldman, LLC
1880 Century Park East, #1600
Los Angeles, CA 90067

Access Requests for California Residents

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