Effective Date: August 20, 2023
This Privacy Policy for California Residents supplements the information contained in OGC’s privacy statement and applies solely to all 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 any terms defined in the CCPA have the same meaning when used in this Policy.
We do not sell or share your information with third parties who are not our service providers.
We collect information as set forth in our Privacy Statement.
In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected | Sold or Shared with Third Parties? | Retention Period |
| 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, to provide goods and services to you | NO | Per our internal policies |
| 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, to provide goods and services to you | NO | Per our internal policies |
| 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). | YES, to provide goods and services to you | NO | Per our internal policies |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO | ||
| 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, to provide goods and services to you | NO | Per our internal policies |
| G. Geolocation data. | Physical location or movements. | NO | ||
| 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. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | ||
| Sensitive Personal Information Category | Government identifiers (social security, driver’s license, state identification card, or passport number) | YES, to provide goods and services to you | NO | Per our internal policies |
| Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password) | NO | |||
| Precise geolocation | NO | |||
| Racial or ethnic origin | YES, to provide goods and services to you | NO | Per our internal policies | |
| Religious or philosophical beliefs | NO | |||
| Union membership | NO | |||
| Genetic data | NO | |||
| Mail, email, or text messages contents not directed to us | NO | |||
| Unique identifying biometric information | NO | |||
| Health, sex life, or sexual orientation information | NO |
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.
Right to Know and Data Portability
You 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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request to [email protected] or by mail to 501 Boylston Street, 10th Floor, Boston, MA 02116.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We 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.
You do not need to create an account with us to submit a request to know or delete.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at [email protected] or by mail to 501 Boylston Street, 10th Floor, Boston, MA 02116.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we 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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your information
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we 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.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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. To make such a request, please send an email to [email protected] or write to us at 501 Boylston Street, 10th Floor, Boston, MA 02116.
If you have any questions or comments about this notice, the ways in which OGC collects and uses your information described here and in our Privacy Statement, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [email protected] or 501 Boylston Street, 10th Floor, Boston, MA 02116.
If you need to access this Policy in an alternative format due to having a disability, please contact us at [email protected] or 501 Boylston Street, 10th Floor, Boston, MA 02116.