California Privacy Notice Statement

California law requires that Alta Genetics (“Alta”) provide you with a summary of your privacy rights under the California Consumer Privacy Act of 2018, as amended (“CCPA”). As required by CCPA, this supplement identifies specific rights regarding certain personal information collected, disclosed and sold by certain businesses. This supplement describes those rights and explains how to exercise them. This supplement does not apply to personal information to which the CCPA does not apply. This supplement applies exclusively to California residents.

Definition: CCPA defines “personally identifiable information” as individually identifiable information about an individual consumer collected online by a corporation from an individual and maintained by the corporation in an accessible form, and may include any of the following: (1) a first and last name; (2) a home or other physical address, including street name and name of a city or town; (3) an email address; (4) a telephone number; (5) a social security number; (6) any other identifier that permits the physical or online contacting of a specific individual; and (7) information concerning a user that the web site collects online from the use, and maintains in personally identifiable form, in combination with an identifier described within this supplement.

Information We Collect
Alta collects 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. In particular, Alta has collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
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.
YES
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, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
YES
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, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information.
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
L. Sensitive information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified, anonymized, or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Alta obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms, verbal questions and answers, or online submissions that you have completed and provided to us related to the services you inquire about or engage us to perform.
  • Indirectly from you. For example, through information we collect from our clients, vendors, or third parties in the course of providing services to you.
  • Directly and indirectly from activity on our websites and applications. For example, from submissions through our website portal or website usage details collected automatically.
  • From third-party data processors or business partners to provide data driven market insight.
  • Publicly available data bases.

Use of Personal Information
Alta may use or disclose the personal information we collect, for either itself or its business partners or associations, 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 share your name and contact information while inquiring about our services, requesting information or materials, or ask a question about our products or services, Alta will use that personal information to respond to your inquiry.
  • To provide you with information, products or services that you request from us.
  • To process your requests, transactions, and payments and prevent transactional fraud.
  • 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.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • 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.

Alta 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 any required notice.

Sharing Personal Information
Alta may disclose your personal information to a third party for a business purpose. In the preceding twelve (12) months, we may have disclosed the following categories of personal information for a business purpose: 

Categories:

Category A: Identifiers
Category D: Commercial information

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

  • Legal entities established pursuant to the Farm Credit Act of 1971, as amended.
  • Contracts and service providers.
  • Third parties with whom we partner to offer products and services to you.

Selling Personal Information
In the preceding twelve (12) months, Alta has not sold any personal information.

Your Rights and Choices: You have the right to request that Alta disclose certain information to you about Alta’s collection and use of your personal information over the past 12 months. Once Alta receives and confirms your verifiable consumer request, Alta will disclose to you:

  • The categories of personal information Alta collected about you;
  • The categories of sources for the personal information Alta collected about you;
  • Alta’s business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom Alta shares that personal information; or
  • The specific pieces of personal information collected about you (also called a data portability request).

You have the right to limit our use of sensitive Information to only the purposes necessary to perform the certain business and commercial purposes described above.

You have the right to correct inaccuracies to your personal information. You may contact us as set forth below to request the correction. We will use commercially reasonable efforts to honor your requests within the limits defined by statute.

Data Retention: For customer data, we generally retain this data for an appropriate period considering the nature of such data and the purposes for which they are processed. Please note that additional retention periods may apply should the data concerned be required to be retained to satisfy our legal or other obligations (such as a pending claim, litigation, law enforcement investigation, government audit or other situation requiring records to be preserved).

Deletion Request Rights: You have the right to request that Alta delete any of your personal information that Alta collected from you and retained, subject to certain exceptions. Once Alta receives and confirms your verifiable consumer request, Alta will delete (and direct our service providers to delete) your personal information from Alta records, unless an exception applies. Alta may deny your deletion request if retaining the information is necessary for Alta or our service providers to:

  1. Complete the transaction for which Alta collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of Alta’s ongoing business relationship with you, or otherwise perform Alta’s contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Alta.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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:

  • Calling us at (800) 932-2855;
  • Contacting us via this webpage or emailing us at [email protected]; and/or
  • mail at the following address: Alta Genetics, N8452 Airport Road, Watertown, WI 53094
 

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 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 Alta collected personal information or an authorized representative;
  • Describe your request with sufficient detail that allows Alta to properly understand, evaluate, and respond to it.
 
Alta cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Requests must indicate the type of request and be accompanied by your full name, California residential address and email address (if available). If submitted by your authorized agent, the request must include the same details plus evidence of your written permission to submit a request on your behalf. Making a verifiable consumer request does not require you to create an account with us. Alta will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: Alta endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Alta requires more time (up to 90 days), Alta will inform you of the reason and extension period in writing. If you have an account with Alta, Alta will deliver its written response to that account. If you do not have an account with Alta, Alta will deliver its written response by mail or electronically, at your option. Any disclosures Alta provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Alta provides will also explain the reasons Alta cannot comply with a request, if applicable. For data portability requests, Alta will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Alta does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Alta determines that the request warrants a fee, Alta will tell you why it made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination: Alta will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Alta will not:

  • Deny you goods or services;
  • 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 goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
 

Last Updated: August 21, 2024