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CONSUMER PRIVACY POLICY

This policy includes information about:

The categories of information that we collect from you during your relationship with us;

How we use and share the information that we collect from you;

Options available to you to instruct us about how your information may be used or shared;

The procedures we follow to protect the information that we collect about you;

Other matters required by law or useful to assist you in protecting your privacy; and

Our affiliated companies.

This policy covers Customer Information, which means personally identifiable information about a consumer or a consumer’s current or former relationship with us.  This policy applies to Career Pathways Consulting.  This policy is provided to you as required by the Federal Financial Privacy Law [15 U.S.C.§§ 6801 – 6810].

      1. Information Collection

We collect your personal information such as your name, email address and phone number. We use that information with your permission in our email marketing and send you emails about our products and services.

2. Information Shared

We may share all the Customer Information that we collect, as described above, for the following purposes:

To provide you with the products and services you requested;

To offer you additional products and services, from us or from others, that may be of interest to you;

To comply with reporting and other legal requirements; and/or

To otherwise conduct business.

3. Procedures for Protecting Nonpublic Personal Information

We are committed to protecting the security and integrity of Customer Information through procedures and technology designed for this purpose.  For example:

(a)

We limit employee access to customer information to those who have a business reason to know this information.  Employees are required to honor our code of conduct, which includes standards to protect customer confidentiality.  They are subject to disciplinary action if they fail to do so.

(b)

We maintain policies and procedures covering the proper physical security of workplaces and records.

(c)

Our physical, electronic, and procedural safeguards meet or exceed federal standards regarding the protection of customer information.

(d)

We require independent contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us.

(e)

We use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware) to protect against unauthorized access or alterations to customer data.

4. Other important information

Direct Marketing:  You can choose not to receive marketing offers from us by direct mail, telephone and/or e-mail.  This preference applies to offers from us about our products and services, and about other products that we think may be of interest to you. 

You may also reduce the amount of e-mail advertising you receive by removing your name from our email list.  Be sure to include complete information about each name, address, telephone number and e-mail address you would like excluded. 

5. California Consumer Privacy Act

Career Pathways Consulting may be considered a “service provider” under the California Consumer Privacy Act (“CCPA”).  The CCPA defines a “service provider” as any entity “that processes information on behalf of a business and to which the business discloses a consumer’s personal information for a business purpose pursuant to a written contract.”  The CCPA defines “personal information,” to include “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”    

Career Pathways Consulting shall refrain from exploiting the personal information that is shared with it by Consumer.  Specifically, Career Pathways Consulting is prohibited from retaining, using or disclosing consumer personal information of Consumer’s clients and customers, or potential clients and customers, for any purpose other than the specific purpose of performing the services specified in this Agreement.  This prohibition includes using or disclosing such personal information for marketing purposes, or any other commercial purpose.