Privacy Notice for California Residents:

Pension Benefit Information, LLC (“PBI” or “we”) works with pension plans, insurance companies, financial institutions, government entities, benefit plan sponsors, and other clients to help locate people who may be eligible for benefits. We also help our clients prevent fraud or avoid overpayment of benefits to deceased individuals.

1. About This Privacy Notice
This Privacy Notice for California Residents (the “Privacy Notice”) supplements the information contained in PBI’s Privacy Policy and applies solely to individuals who reside in the State of California (“consumers” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 to 1798.199) (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Where noted in this Privacy Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from some of its requirements.

2. Collection of Your Personal Information
PBI collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, PBI has collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. 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, or other similar identifiers. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, address, telephone 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.

Some personal information included in this category may overlap with other categories.

Yes
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No
F. Internet or other similar network activity. Browsing history, search history, information regarding a consumer’s interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. No
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No
I. Professional or employment-related information. Current or past job history, performance evaluations, human resources file, or employer/affiliated company name. Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No
K. Inferences drawn from other personal information. Inferences drawn to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No

Personal information does not include:

  • Publicly available information from federal, state and local government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994 (“DPPA”).

PBI obtains the categories of personal information listed above from the following categories of sources:

  • From third parties pursuant to a servicing, licensing or vendor contract.
  • From government sources, state, local and federal governments.
  • From published obituaries and death notices.
  • Directly from you, including employment applications/forms, phone, mail or internet forms, or in-person contact.
  • Indirectly from your use of PBI’s website or applications or your attendance at marketing-related events, such as conferences.
  • From purchasing marketing lists from third parties.

3. Use of Your Personal Information
PBI may use, sell, or disclose the personal information it collects for one or more of the following business purposes:

  • To perform services pursuant to servicing contract, including but not limited to matching to death records, identifying maturities, and confirming address and contact information for clients.
  • To fulfill or meet the reason you or a third party provided the information.
  • To offer customized content and individualized personalization of PBI’s services and websites to make them more relevant to your or a third party’s interests and needs.
  • To notify you or a third party about changes or updates to PBI’s services and other products.
  • To provide you or a third party with information about PBI’s services as well as other products, events and services of ours or our affiliates.
  • To invite you or a third party to participate in surveys
  • To respond to your or a third party’s requests, inquiries, comments and concerns.
  • To provide, evaluate and improve PBI’s services and other products, and to develop new products, services and benefits.
  • To identify usage trends and for data analysis, including for purposes of research, audit, reporting and license fees to third-party providers, such as data providers, or in other ways to which you have expressly agreed in a customer agreement.
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • To debug to identify and repair errors that impair existing intended functionality.
  •  Short-term transient use, provided your personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual customer’s experience outside the current interaction, including, but not limited to, the contextual characterization of ads shown as part of the same interaction.
  • To conduct internal research for technological development and demonstration.
  • To perform activities to verify or maintain the quality or safety of a service or device that is owned or controlled by PBI, and to improve, upgrade, or enhance the service or device that is owned, or controlled by PBI.
  • To provide technical, product and other support and to help keep PBI’s services working, safe and secure.
  • To perform services on behalf of PBI or our service providers, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of PBI or our service providers.
  • To provide employee benefits and comply with employment laws and regulations.
  • To comply with our legal obligations, resolve disputes, and enforce our agreements.

We may also match or combine the personal information that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above.

PBI 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 or updating this Privacy Notice.

4. Sharing of Your Personal Information
PBI may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Section 5.E. Personal Information Sales Opt-Out Rights). When PBI discloses personal information for a business purpose to PBI’s service providers, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except as set forth in the contract.

We share your personal information with the following categories of third parties:

  • Our corporate affiliates on a need to know basis and subject to an intercompany agreement.
  • Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, and customer support, and to process the information for us based on our instructions and in compliance with this Privacy Notice and any other appropriate confidentiality and security measures.
  • Our clients pursuant to servicing or licensing agreements.

 A. Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, PBI has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category C: Protected classification characteristics under California or federal law
  • Category F: Internet or other similar network activity
  • Category I: Professional or employment-related information

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our corporate affiliates on a need to know basis and subject to an intercompany agreement.
  • Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, and customer support, and to process the information for us based on our instructions and in compliance with this Privacy Notice and any other appropriate confidentiality and security measures.
  • Our clients pursuant to servicing or licensing agreements.

B. Sale of Personal Information

In the preceding twelve (12) months, PBI has sold the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category C: Protected classification characteristics under California or federal law

We sell your personal information to the following categories of third parties:

  • PBI’s clients, including but not limited to: pension plans, insurance companies, financial institutions, healthcare providers, government entities, benefit plan sponsors, healthcare researchers, and other legitimate businesses. When PBI collects your personal information, we make that information available to a client with a legitimate business purpose. PBI’s clients hire PBI for reasons such as helping to prevent fraudulent overpayments, identifying when a beneficiary may be eligible to receive benefits, or locating individuals and updating their contact information.

5. Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

A. Access to Specific Information and Data Portability Rights

You have the right to request that PBI disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Section 5.C. Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources from which we collected your personal information.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

 B. Deletion Request Rights

You have the right to request that PBI delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Section 5.C. Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

C. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

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 related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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 or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Section 5.E. Personal Information Sales Opt-Out Rights.

D. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) additional days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

E. Personal Information Sales Opt-Out Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: https://www.pbinfo.com/dnsmpi/.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

6. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7. Changes to this Privacy Notice
PBI reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on PBI’s website and will update the Privacy Notice’s effective date. Your continued use of PBI’s Website and services following the posting of changes constitutes your acceptance of such changes.

8. Contact Information
If you have any questions, comments or requests about this Privacy Notice, the ways in which PBI collects and uses your information described in this Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under the CCPA, please do not hesitate to contact us at:

Phone: 1-800-327-2720
Website: www.pbinfo.com
Postal Address:
Pension Benefit Information, LLC
Attn: Peter Shin, CCPA Consumer Request
900 Larkspur Landing Circle, Suite 201
Larkspur, CA 94939

If you use assistive technology (such as a Braille reader, a screen reader, TTY, etc.) and the format of this Privacy Notice interferes with your ability to access this Privacy Notice, please contact PBI for assistance. Please indicate the nature of your accessibility problem, the preferred format you would like to receive this Privacy Notice, and your contact information so that we may respond in a manner most helpful to you.

Effective Date: 1/1/2020
Last Revision: 12/6/2019

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