The California Consumer Privacy Act (“CCPA”) was passed on by the California State Legislature and signed into law on June 28, 2018. The law goes into effect starting January 1, 2020. More information on the CCPA is available from the California Office of the Attorney General.

This statement addresses Quandary Consulting Group’s activities as a Business as described in the California Consumer Privacy Act. This statement supplements our Privacy Policy. In the event of a conflict between this statement and our Privacy Policy, this statement shall control as it relates to California Residents.

CCPA Consumer Rights Info

The CCPA enhances privacy rights and consumer protection for residents of California by allowing California residents more control over how companies collect and use their personal information.

Under CCPA, California consumers have the right to:

• request details regarding the personal information we collect (including how we use/ disclose this information), and request corrections to this personal information*
• delete their personal information*
• opt-out of any “sales” that may be occurring
• not be discriminated against for exercising these rights

*Please note, your right to access and right to deletion are not absolute and are subject to certain exceptions.

For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of the business’s systems of networks.

How to Exercise Your Rights Under the CCPA

Under our current practices and business implementation, we do not sell personal information. California consumers may make a request pursuant to their rights under the CCPA by emailing us at info@quandarycg.com.

Please include “CCPA REQUEST” in the subject line of your email.

When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the email address stated above. If we receive your request at a different email or mailing address, we will respond within a reasonable period of time.

Please note that we are only required to respond to each customer once per calendar year.

CCPA Disclosures

Here are details about the personal information that we collect and share. For more information, please see our Privacy Policy [link].

Information We Collect

To better engage with you, we may collect certain information directly from you, from third parties with whom we partner, and from publicly available sources. The below list provides an overview of our Personal Information collection practices for California residents and includes terms defined under the CCPA, including but not limited to the categories of information listed:

• identifiers such as your name and email address,
• employment information, e.g., where you work,
• commercial information, for example, details of what prospective customers choose to purchase (or not to purchase) from Quandary Consulting Group
• inferences we draw about you, for example, based on your relationship with Quandary Consulting Group,
• electronic network data such as IP address and user agent.

Information We Disclose for Business Purposes

We have limited relationships with third parties to assist us in providing the best experience possible when you interact with Quandary Consulting Group.

• Perform Services/ Short-Term Uses. We share information we collect with tools maintained by third parties to help us connect with you, customize your experience, and provide access to Quandary Consulting Group resources.
• Security. We use third-party tools to manage and secure traffic and activities on our website.
• Audit. We rely on third-party platforms and service providers to help us meet our financial, governance, and regulatory obligations and to support our analytics teams.

Whenever possible we share information in an aggregate, de-identified, or anonymized format. Information is only shared to the extent necessary to perform these functions.

As stated in our privacy policy, “These [third party] service providers are contractually required to maintain the confidentiality of the information we provide them. The contracts outline the appropriate use and handling of your information and prohibit third parties from using any of your personal information for purposes unrelated to the product or service for which they’ve been contracted.”