Privacy Notice for California Residents

Effective Date: as of January 1, 2020

Kaufman, Hall and Associates, LLC ("Kaufman Hall" or "we") is pleased to present this Privacy Notice for California Residents (“Notice”), which supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). This notice explains the categories of personal data that we collect from you and how we collect and use personal data that is subject to the California Consumer Privacy Act of 2018 (the “CCPA”). It further describes the rights that California residents have with respect to their personal data.

This Notice should be read together with the Privacy Policy, and in case of any conflict the terms of this addendum will prevail as to personal data of California residents that is subject to the CCPA. Any terms used in this Notice have the same meaning of any terms defined in the CCPA, including the term “personal data,” which includes all “personal information” as defined in the CCPA.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see Kaufman Hall’s Privacy Policy). Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

Information We Collect

Our Website 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, household, or device ("personal information"). Please also note that the definition of “personal information” under CCPA is subject to certain exceptions as set forth therein and does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope.

In addition to the information in our General Privacy Notice, our Website may have collected the categories of personal information listed below from its consumers within the last twelve (12) months. Please note that the following list represents categories of personal data across all California residents whose personal data we may have collected or received and does not necessarily represent information we have collected specifically about you. 

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

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• 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 set forth in 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 about our Website users/consumers is among the assets transferred.

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.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter 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, Company has disclosed the following categories of personal information for a business purpose:

Sales of Personal Information

We do not sell the personal information of consumers, but we may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other personal data via automated technologies on www.kaufmanhall.com in exchange for non-monetary consideration. When browsing our Website, unless specifically requesting event registration or a service, personally identifiable information is not collected. However, through the use of “cookies” and other technologies, we track information relating to your usage of our Website that allows us to evaluate the usefulness of our Website, diagnose problems with our server, administer the Website, analyze trends, and gather broad demographic information for aggregate users. This information cannot be tracked to an individual and is used only for statistical reporting. Cookies on our website are deployed by third party provides, including Marketo, Inc., 6sense Insights, Inc., and Google and can be broadly categorized as follows:

1. Essential/strictly necessary cookies, which are essential to the functioning of the Website.
2. Behavioral advertising/targeting cookies in our Website.
3. Functional cookies, which are used to enhance consumer’s experience (e.g. remember settings).
4. Performance cookies to measure Kaufman Hall Website's performance and improve website user’s experience. 
5. Social media cookies, which allow Kaufman Hall to share the content on its Website on social media.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

• Access to Specific Information and Data Portability Rights. You may have the right 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 (see Exercising Access, Data Portability, and Deletion Rights), we may disclose to you: (a) the categories of sources for the personal information we collected about you; (b) Our business or commercial purpose for collecting or selling that personal information, (c) the categories of third parties with whom we share that personal information, (d) The specific pieces of personal information we collected about you (also called a data portability request); (e) the categories of personal data disclosed for a business purpose or sold to third parties and the categories of third parties to whom such personal data was sold or disclosed. 

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

• Deletion Request Rights. You have the right 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 (see 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 do not provide these deletion rights for B2B personal information.

• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) Deny you goods or services; (b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (c) Provide you a different level or quality of goods or services; (c) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; (d) however, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
• Right to opt-out. You may have the right to request that your personal data not be sold to third parties.
• Other California Privacy Rights. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Kaufman Hall does not disclose personal information to third parties for their direct marketing purposes.

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:

• Calling us at:
  (847) 441-8780
  (8:30 a.m. - 5:00 p.m. Central time)
• Online:
  You may send us your comments and request information using our online form.
• Writing us at:
  5202 Old Orchard Road, Suite N700 Skokie, IL 60077
• E-mailing us at:
  Compliance@kaufmanhall.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

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, including your and your authorized agent’s, if applicable, first and last name, email address, physical address, telephone number, and description of relationship to Company. You may also include additional information based on the nature of your request and your relationship 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.

After we verify your identity and the validity of your request, we will take the following action free of charge:

• in the case of an access request, provide you any required personal data covering the twelve (12)-month period preceding your request; and
• in the case of a deletion request, delete personal data that we have collected about you, subject to our right to maintain your personal data for specific purposes permitted under CCPA. 

• We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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 post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact for more Information

If you have any questions or comments about this notice, the ways in which Kaufman Hall collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at Compliance@kaufmanhall.com