These disclosures supplement the Privacy Policy (the “Policy”) of Antares Enterprises, Inc., DBA Tier 11 (“Tier 11”), a Massachusetts corporation, which can be found at http://www.tiereleven.com/ (the “Site”). They are provided pursuant to the California Consumer Privacy Act (the “CCPA”) and apply only to residents of California. Each capitalized term used, but not defined, in these disclosures shall have the meaning given to such term in the CCPA.
Required Disclosures
Categories of Personal Information Collected
The following categories of personal information are collected by the Tier 11:
- Identifiers (e.g. name, Internet protocol address, email address, physical address, and phone number);
- Professional or Employment-Related Information;
- Education Information;
- Bank account number, credit card number, debit card number, or other financial information
- Internet and Network Activity Information; and
- Commercial Information.
Categories of Sources of Personal Information Collected
Tier 11 obtains personal information from consumers using the Site, individuals or entities using the Site on behalf of consumers, or individuals or entities with whom or which Tier 11 has a business relationship. Tier 11 may also obtain personal information from clients and employees in the ordinary course of business.
Purposes for Collecting Personal Information
Tier 11 uses personal information collected by it for one or more of the following purposes:
- To achieve the purposes for which you, an individual or entity acting on your behalf, or an individual or entity with whom or which Tier 11 has a business relationship, provided personal information;
- To enable Tier 11 to perform the marketing services contemplated under the service agreement with customers;
- To provide you with support, and to respond to your questions, regarding the services of Tier 11;
- To record use of the Tier 11’s website, to diagnose problems with the website, and to improve and make the website more useful to consumers;
- To send e-mail messages, newsletters and other relevant information about the Tier 11’s marketing services;
- To process payments for Tier 11’s marketing services;
- To consider consumers for employment or employ consumers;
- To administer employment benefits or distribute wages;
- To respond to requests from law enforcement or other governmental authorities;
- To comply with any applicable law or legal obligation;
- To prosecute or defend itself in a legal dispute or proceeding; and
- For any other business purpose permitted by the CCPA.
Categories of Third Parties with whom The Firm Shares Personal Information
Tier 11 does not sell any personal information to Third Parties. Tier 11 may share personal information—including any category of personal information collected by the Firm—with Third Parties that enable Tier 11 to render legal services. Categories of Third Parties with whom the Firm may share personal information include vendors that provide the following services to Tier 11:
- [to be completed by Tier 11] (examples could include: credit card processing, accounting systems, business intelligence/financial analysis, document management systems, collaboration sites, faxing, email, email management and security, payroll and benefits systems, contact relationship management systems, Cloud storage, applications for tracking and managing employee benefits data).
Summary of Consumers’ Rights
The following is a summary of a consumer’s rights under the CCPA:
Access to Specific Information and Data Portability Rights
You have the right to request that Tier 11 disclose certain information to you regarding your personal information collected by Tier 11 as follows:
- The categories of personal information collected about you;
- The categories of sources of the personal information collected about you;
- Tier 11’s business or commercial purpose for collecting or, if applicable, sharing your personal information;
- The categories of third parties with which or whom Tier 11 shares your personal information;
- The specific pieces of personal information collected about you;
- The categories of personal information, if any, Tier 11 disclosed for a business purpose to a third party in the preceding 12 months.
Deletion Rights
You may request that Tier 11 delete any of your personal information retained by it, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, Tier 11 will delete (and direct its service providers to delete) such personal information from Tier 11’s (or such service providers’) records, except that Tier 11 may deny your request if retaining the personal information is necessary for Tier 11 or one of its service providers to:
- Complete the transaction for which Tier 11 collected the personal information, provide the marketing service requested by you, take actions reasonably anticipated within the context of Tier 11’s ongoing business relationship with you, or otherwise perform a contract between the Tier 11 and you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
- Debug products to identify and repair errors that impair intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided by law;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with Tier 11;
- Comply with a legal obligation; and
- Make other internal and lawful uses of personal information that are compatible with the context in which you provided it.
Verifiable Consumer Requests
To exercise your rights described in these disclosures, you must submit a verifiable consumer request to Tier 11 as set forth in the Policy. 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 relating 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 Tier 11 to reasonably determine you are the person about whom Tier 11 collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows Tier 11 to properly understand, evaluate, and respond to it.
Tier 11 cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. Tier 11 will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Tier 11’s Response
Tier 11 endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Tier 11 requires more time (up to an additional 45 days), Tier 11 will inform you of the reason and extension period in writing. Tier 11 will deliver its written response by mail or electronically, at your option. Any disclosures provided by Tier 11 will only cover the 12-month period preceding receipt of the verifiable consumer request. The response provided by Tier 11 will, if applicable, also explain the reasons it cannot comply with a request. For data portability requests, Tier 11 will select a format to provide your personal information that is readily useable and should allow you to electronically transmit the information from one entity to another entity without hindrance.
Tier 11 does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Tier 11 determines that any request warrants a fee, it will tell you why a fee is warranted and provide you with a cost estimate before completing your request.
No Discrimination
Tier 11 will not discriminate against you for exercising any rights under the CCPA. In particular, if you exercise any such rights, Tier 11 will not:
- Deny you services or access to your client file;
- 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 services; or
- Suggest that you may receive a different price or rate for services, or a different level or quality of services.
Revisions
Tier 11 may revise these disclosures from time to time by posting the revisions on the Site. Any such revision will take effect immediately upon such posting, but will only relate to personal information collected after such revision is posted. It is your responsibility to periodically check the Site for revisions to these disclosures.
Dated: July 1, 2020
