California Consumer Privacy Act Disclosures

These disclosures are provided by Partners in Leadership, LLC, a California limited liability corporation doing business as Culture Partners (“Company”) and applies solely to residents of the State of California (“consumers” or “you”) with respect to personal information Company processes as a business. Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations (“CCPA”) have the same meaning when used in these disclosures. These disclosures do not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception or exemption under the CCPA applies. You can download a pdf version of these disclosures.

1. Notices at Collection

We have set out below categories of personal information about California resident website visitors, customers, prospective customers, corporate representatives of our vendors and other partners, and job applicants and other potential employees. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.

Website Visitors:

What Categories of Personal Information Do We Collect?

Non-Sensitive Personal Information:

• Identifiers such as a real name, alias, email address, country, company name or other similar identifiers.
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to name and job title but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records.

Sensitive Personal Information:

• None

For What Purposes Do We Collect and Use Personal Information?

We use personal information about our website visitors as reasonably necessary and proportionate to:

• To perform the services or provide the goods reasonably expected by our website visitors;
• To market to you; and

We do not sell or share for cross context behavioral advertising any personal information of California residents or respond to do not track signals. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.

What Criteria Do We Consider When Retaining Personal Information?

In general, with respect to each category of personal and sensitive personal information about website visitors, we retain each category for the longer of: as long as needed or permitted in light of the purpose(s) for which it was obtained and any additional time periods necessary for the compliance with laws, exercise or defense of legal rights, and archiving, back-up and deletion processes.

Podcast and Newsletter Subscribers and Giveaway Contestants:

What Categories of Personal Information Do We Collect?

Non-Sensitive Personal Information:

• Identifiers such as a real name, alias, email address, or other similar identifiers.
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to name, alias, email address but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records.
• Company name, title or information, if provided.

For What Purposes Do We Collect and Use Personal Information?

We use personal information about you as a customer, prospective customer, corporate representative of our vendors and other partners as reasonably necessary and proportionate for the purposes of:

• To perform the services or provide the goods reasonably expected by you To market to you; and

We do not sell or share for cross context behavioral advertising any personal information of California residents. The California Consumer Privacy Act Privacy Policy is in section 2 of these disclosures.

What Criteria Do We Consider When Retaining Personal Information?

In general, with respect to categories of personal information about customers, prospective customers, corporate representatives of our vendors and other partners, we retain each category for the longer of: time periods necessary for the provision of Services, giveaway deadlines, compliance with laws, exercise or defense of legal rights, and archiving, back-up and deletion processes.

2. California Consumer Privacy Act Privacy Policy

Last Updated: February 15, 2024

Our Personal Information Handling Practices in 2024

In the CCPA Table below, we have set forth categories of personal information about California residents we have collected, and as applicable disclosed, for a business purpose in the preceding 12 months. The table is followed by a description of the purposes for which we collected personal information. In the preceding 12 months we did not sell or share for cross context behavioural advertising, the personal information of California residents. If we process de-identified information, we will maintain the information in a deidentified form and not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether deidentification processes used satisfy legal requirements.

Business or Commercial Purpose for Collecting Personal Information

• To perform the services or provide the goods reasonably expected by consumers; To market to consumers such as website visitors, customers, prospective customers, corporate representatives of our vendors and other partners.

We do not have actual knowledge that we sell or share for cross context behavioral advertising, the personal information of California residents under 16 years of age.

CCPA Rights
As a California resident, you have the following rights under the CCPA

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You may only exercise your right to know twice within a 12-month period.
• The right to delete personal information that we have collected from you, subject to certain exceptions.
• The right to correct inaccurate personal information that we maintain about you.
• The right to opt-out of the sale or sharing of your personal information by us. We do not sell or share for cross-context behavioral advertising any of the categories of personal information that we collect about California residents.
• The right to limit our use and disclosure of sensitive personal information to purposes specified in Cal. Civil Code 1798.121(a). We do not use or disclose sensitive personal information for purposes other than those specified in Cal. Civil Code 1798.121(a).
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125, including an employee’s, applicants’, or independent contractors’ right not to be retaliated against for the exercise of their CCPA rights.

How to Exercise CCPA Rights

Methods of Submission and Instructions: To submit a request to exercise your rights to know, delete or correct, please email legal@culturepartners.com or call 1-800-504-6070.

Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent by taking the steps outlined under “Authorized Agent” further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.

Authorized Agents:  You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and
• You directly confirm with the Company that you provided the authorized agent with permission to submit the request.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Contact Us

If you have any questions or comments about these disclosures or our practices, please contact us at:

Email address: legal@culturepartners.com

Postal address: 27555 Ynez Road, Suite 200, Temecula, CA 92591