Privacy Notice to California Residents


EFFECTIVE DATE:  January 1, 2020
Last Reviewed:  December 23, 2019

This PRIVACY NOTICE TO CALIFORNIA RESIDENTS supplements the information contained in the Privacy Notice and Data Processing and Privacy Notice of State Street and its subsidiaries and assigns (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Please note that certain exemptions apply to your rights and State Street’s obligations pursuant to the CCPA.  These rights and requirements may not apply in certain situations depending on your relationship with State Street, State Street’s other legal obligations and as otherwise provided for in the CCPA.

This notice contains the following sections:

  • Information we collect
  • How we collect your information
  • Use of personal information
  • Disclosure of personal information for a business purpose
  • No sale of personal information
  • Your rights and choices
    • Access to specific information and data portability rights
    • Deletion request rights
    • Exercising access, data portability, and deletion rights
    • Response timing and format
  • Children under sixteen personal data
  • Non-discrimination
  • Changes to our privacy notice
  • Contact information

 

Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we may have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

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, passport number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number,  education, employment, employment history.  Some personal information included in this category may overlap with other categories.

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, , sex (including gender).

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information.

Identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, keystroke,.

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

G. Geolocation data.

Physical location or movements.

H. Sensory data.

Audio, electronic, visual, or similar information.

I. Professional or employment-related information.

Current or past job history.

J. Inferences drawn from other personal information.

Profile reflecting a person's household, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


How We Collect Your Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Direct interactions with you, for example, filling out forms, mail or electronic correspondence, telephone or in person. 
  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our websites and our mobile app. For example, from submissions through our website portal or website usage details collected automatically.
  • From affiliates and third parties service providers (such as our marketing partners) acting on our behalf in connection with the services we perform.
  • From publicly available sources, including via social media, to the extent that you manifestly choose to make your profile publicly visible.   
  • Automated technologies or interactions that collect technical data about a user’s equipment, browsing actions and patterns. This personal data is collected by using cookies, server logs or other similar technologies.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order to open, manage and administer your account, we will use that information to for such purpose on an ongoing basis.
  • To provide you with information, products or services that you request from us.
  • To provide you with, email alerts, event registrations social media activity, and other notices concerning our products or services, or events or news that may be of interest to you, including through targeted messages and advertisements on or through our websites and apps and through third-party websites and apps. For more information, please see our privacy notice. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you in a tailored and personalized manner.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others and to prevent fraud.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise permitted by the  CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Authenticate you as an authorized user and to facilitate communications between us that you request. We 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.

Disclosing Personal Information for a Business Purpose

We may disclose your personal information to our affiliates, service providers, and other third parties for our business purposes.  When we do so, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories (as described above) of personal information for a business purpose:

Category A:            

Identifiers.

Category B:            

Personal information categories listed in the California Customer Records statute.  

Category C:            

Protected classification characteristics under California or federal law.

Category D:            

Commercial information. 

Category E:             

Biometric information.

Category F:             

Internet or other similar network activity.

Category G:            

Geolocation data.

Category H:            

Sensory data.

Category I:            

Professional or employment-related information.

Category J:            

Inferences drawn from other personal information.

 

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

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

No Sale of Personal Information

In the preceding twelve months, we have not sold any personal information, including personal information of minors under the age of 16.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information, subject to certain exceptions defined in the CCPA and other applicable laws and regulations. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • 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).

Deletion Request Rights

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that we 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, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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:

One Lincoln Street, SFC0206
Boston, MA 02111
Attn: Privacy Office

Once we receive a request from you, we will first verify your identity.

 If you are a client and have an account with us, we will verify your identity by either allowing you to use our existing authentication practices or by asking you to provide your account number, address and utility bill and matching them with data points we have on file.

If you are not an accountholder, we will verify your identity by asking you to provide your email address, home address and utility bill and  matching them with data points we have on file. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm the personal information relates to you or whether you, as an agent, have the authority to make the request on behalf of another. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Authorized Agent

Only you, or a person you have designated in writing as your authorized agent, or whom is 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.

To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf (including a power of attorney). We will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Non-Discrimination

We will not discriminate against you for exercising any of rights under the CCPA.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

One Lincoln Street, SFC0206
Boston, MA 02111
Attn: Privacy Office