California Consumer Privacy Act (CCPA)

Last Updated: [3/14/2024]

This Privacy Notice (“Notice”) provides additional specific information for “Consumers” as defined in the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act (“CPRA”). This Notice is a supplement to other privacy policies or notices issued by Williams (“Company”, “We”, “Us”, or “Our”). In the event of a conflict between any other Williams policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA and CPRA.

In accordance with the CCPA’s and CPRA’s requirements, this Notice describes our collection, use, disclosure of California Consumers’ “Personal Information” or “PI” as defined by the CCPA and CPRA, as well as the rights California Consumers have under the CCPA and CPRA. Terms defined in the CCPA and CPRA that are used in this Notice have the same meanings as the CCPA and CPRA.

The following rights are also available to residents of the following states:

• The Right to Opt Out of Certain Processing: Colorado, Connecticut, Virginia
• The Right to Opt In for Sensitive Data Processing: Colorado, Connecticut, Virginia
• The Right Against Automated Decision Making: Colorado, Connecticut, Virginia

Disclosure of Personal Information, No Sale:

Williams has not sold Personal Information (as defined or as contemplated by the CCPA or CPRA) in the preceding twelve (12) months. As defined and contemplated by the CCPA and CPRA, Williams does not sell Personal Information of minors under the age of sixteen (16).

California Consumer Privacy Rights

As a California Consumer, you have the following rights:

• Right to Disclosure: California Consumers have a right to request information from us regarding the Personal Information we collect and disclose for business purposes about you, the consumer.
• Right to Deletion: In certain circumstances, you have the right to request we delete Personal Information we collected from you.
• Right to Non-Discrimination: Williams will not discriminate against California Consumers for exercising their rights under the CCPA or CPRA.
• The Right to Opt-Out of the Sharing of Your Personal Information
• The Right to Correct Inaccurate Personal Information
• The Right to Limit Use and Disclosure of Sensitive Personal Information
• The Right Against Automated Decision Making

Collection and Use of Personal Information

We 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 household (“personal information”).

The following is a description of our data collection practices, including the personal data we may collect, the source of that information, the purposes for which we collect information (in addition to as otherwise set forth herein), and whether we disclose that information to external parties. We may use any and all of the information for any purposes described in this Privacy Notice. We may not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purposes for which the personal information was collected, without providing consumers with notice.

Our collection, use, retention, and sharing of a consumer’s personal information shall be necessary and proportionate to achieve the purposes for which such information is collected or processed, or for another disclosed purpose that is compatible with the context in which the personal information was collected, and not further processed in a manner that is incompatible with those purposes.

We may not retain a consumer’s personal information or sensitive personal information for each disclosed purpose for which the personal information was collected for longer than is reasonably necessary for that disclosed purpose.

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

Below is a list of categories of personal information and a discussion as to whether we have collected any such information within the past twelve (12) months:

PERSONAL IDENTIFIERS

• We collect your name, address, email address, zip code, telephone number, date of birth, phone number, and other similar personal identifiers when you create an account with us or it is provided to us. We use this information to provide our Services, as well as to respond to your requests.
• We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity, and measure the effectiveness of online services, applications, and tools.
• We collect your Device ID automatically when you use our Services. We use this information to monitor your use and in furtherance of providing our Services to you.
• Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application.

CUSTOMER RECORDS INFORMATION AND PERSONAL DATA PROTECTED AGAINST SECURITY BREACHES (CAL. CIV. CODE § 1798.80(E))

• We collect your name, phone number, username, password, company name, job title, business email address, and department when you create an account with us or provided to us. We use this information to provide our Services and to respond to your requests.
• We may collect banking information in order to provide the Services.
• We collect life or health insurance or other financial services information directly from you or from records provided to us. We may use this information to provide you with the Services.

PROTECTED CLASSIFIED INFORMATION

• We do not collect protected classified information.

COMMERCIAL INFORMATION

• When you engage with us, we create records of your interactions with us and the Services provided. We use this information to measure the effectiveness of our Services and use this information to better calibrate our assessment tool.

BIOMETRIC INFORMATION

• We do not collect any biometric information about you.

INTERNET OR OTHER SIMILAR NETWORK ACTIVITY

• We collect information regarding your interaction with our Website. This includes device(s) used to access the services and information regarding your interaction with our Website or Services and other usage data.

GEOLOCATION

• As described above, we collect your IP address automatically when you use our Site. We can determine your general location based on the IP address, but not your precise geolocation.  Williams does not collect data related to your precise geolocation.

AUDIO/VIDEO DATA

• If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect sensory information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law. We do not collect thermal, olfactory, or similar information.

PROFESSIONAL OR EMPLOYMENT RELATED INFORMATION

• We collect business information, including your name, company, and job title, and business contact details from you. We use this information to reach out to you in furtherance of the provision of our Services.

EDUCATION INFORMATION

• We do not collect any information about the institutions you have attended.

SENSITIVE PERSONAL INFORMATION (See Below)

Sharing your Data and the Recipients of your Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) strategic partners; and (iii) analytics providers.

When we disclose personal information for a business purpose, 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 in performance of the contract.  The CCPA and CPRA prohibit third parties who receive the personal information we hold from selling it unless you have received explicit notice and an opportunity to opt-out of such downstream sales.

Either we or our Service Providers may use your information for the following Business Purposes (as defined in the CCPA and CPRA) on a day-to-day basis:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Do We Sell or Share Your Personal Information?

As mentioned above, we do not sell your personal information as currently defined under the CCPA and as amended by the CPRA, meaning that we do not rent, disclose, release, transfer, make available or otherwise communicate your personal information to a third party for monetary or other consideration. We will not sell your information unless we modify this Privacy Policy and take the additional steps required under the CCPA.

While we do not sell Personal Information for monetary value, we may share it with a third party or disclose it to a service provider or contractor in furtherance of a business purpose.  In accordance with the CPRA, you have the right to opt-out of Williams sharing or otherwise disclosing your personal data. If you choose to opt-out of Williams sharing your data, you can do so by emailing us at [email protected].

If we do share your Personal Information with a third party, Williams shall enter into an agreement with such third party, service provider, or contractor that: (1) specifies that the personal information is disclosed by Williams only for limited and specified purposes; (2) obligates the third party, service provider, or contractor to comply with applicable obligations under the CPRA and obligate those persons to provide the same level of privacy protection as required by the CPRA; (3) grants Williams rights to take reasonable and appropriate steps to help ensure that the third party, service provider, or contractor uses the personal information transferred in a manner consistent with the Williams’ obligations under the CPRA; (4) requires the third party, service provider, or contractor to notify us if it makes a determination that it can no longer meet its obligations under the CPRA; and (5) grants Williams the right, upon notice, including under (4), to take reasonable and appropriate steps to stop and remediate unauthorized use of Personal Information.

Under the right to delete provisions of the CPRA, Williams will enter into an agreement with a third party that (1) the service provider or contractor shall cooperate with the Company in responding to a verifiable consumer request; and (2) that at the direction of Williams, shall delete, or enable Williams to delete, and shall notify any of its own service providers or contractors to delete, personal information about the consumer collected, used, processed, or retained by the service provider or the contractor.

Additionally, the service provider or contractor shall notify any service providers, contractors, or third parties who may have accessed personal information (requested for deletion) from or through the service provider or contractor, unless the information was accessed at the direction of Williams, to delete the consumer’s personal information, unless doing so proves impossible.  A service provider or contractor shall not be required to comply with a deletion request submitted by the consumer directly to the service provider or contractor to the extent that the service provider or contractor has collected, used, processed, or retained the consumer’s personal information in its role as service provider or contractor to Williams.

How Long Do We Keep Your Data?

For each of the categories of personal data and for the sensitive personal data, below please find information regarding how long we keep such data or how we will decide to dispose of such data.

• Personal Identifiers:
  • We collect this data as provided by you to us, and we utilize this data in furtherance of providing Services to you. We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Customer Records Information:
  • We collect this data when you create an account with us and use it to provide Services to you. We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Protected Classified Information Under California Law:
  • We collect information about you, including your age and date of birth, when you create an account with us or if you provide this information to us. We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes
• Commercial information:
  • When you create an account or otherwise engage with us via our Website or app, we create records of your interactions with us and the Services provided. We utilize this information to measure the effectiveness of our Services. We keep the data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Biometric Information:
  • Williams does not collect any biometric data.
• Internet and other electronic network activity:
  • We collect information regarding your interaction with our Website. This includes device(s) used to access the Website and information regarding your interaction with our Website or in the provision of our Services to you. We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Geolocation Data:
  • As described above, we collect your IP address automatically when you use our Site. We can determine your general location based on the IP address, but we do not and cannot determine your precise geolocation. We keep this data until we determined that it is no longer needed to achieve our business-related purposes, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Audio, electronic, visual, thermal, olfactory, or similar information:
  • If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of such call.  We may collect the content, audio, and video recordings of conference calls between you and us that we record where permitted by you and/or by law.  We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.  We do not collect thermal, olfactory, or other similar information.
• Professional or employment-related information:
  • We collect business information, including your name, company, job title, and business contact details from you which you provide to us. We use this information in furtherance of our Services.  We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.
• Sensitive Personal Information (See Below).

Do We Use your Data for Automated Decision Making?

            We do not use your data for automated decision making (i.e. data profiling) purposes.

How to Exercise Your Rights Under the CCPA/CPRA

Under the CCPA and CPRA you have the right to find out about the personal information that we have collected and how that information has been used or disclosed. You also have the right to request that we delete or correct your personal information (and/or opt-out of the sale or sharing of your personal information).

If you wish to exercise any of these opt-out rights, or if you would like additional information, please contact us at the following email address: [email protected], or call us at the following toll-free number: (888) 700-0096.

1. The Right to Access and Know About Personal Information Collected, Disclosed, or Shared

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 twelve (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 to whom we disclose that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.

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.

2. The Right to Request Deletion of Your Personal Information by Williams and Third Parties

Subject to certain exceptions, you have the right to request that we delete any of all of your personal information that we collected from you and retained over the past twelve (12) months. Please bear in mind that deletion of your personal information may not allow Williams to continue to provide the Services to you.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers or contractors to delete) your personal information from our records, unless an exception applies. Additionally, upon receiving a verifiable consumer request, we will notify all third parties to whom Williams has shared such personal information to delete the consumer’s personal information, unless doing so is proven to be impossible or involves disproportionate effort.  You may request that only a portion of your information be deleted.

We may deny all or part of your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated based on our ongoing business relationship with you, or otherwise perform our agreement with you
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
• Debug products to identify and repair errors that impair existing intended functionality
• Exercise free speech or ensure the right of another consumer to exercise their right of free speech or other right provided for by law
• Engage in public or peer reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information
• Comply with a law or a legal obligation

Williams may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with other laws, or for other purposes solely to the extent permissible under the CPRA.

3. The Right to Opt-Out of the Sharing of Your Personal Information

“DO NOT SELL OR SHARE MY INFORMATION”

The CCPA and CPRA provide you with the right to opt out and stop businesses from selling or sharing your personal information.  This right applies to all California consumers ages 16 or older and may be exercised at any time.

The right to opt out of sharing personal information includes sharing with a third party even when there is no exchange of consideration between the parties. This can include the right to opt out of Williams using technologies like cookies and pixels to track you across other websites, apps, or services that then share that information with ad networks to deliver targeted advertisements to you.

If you are 16 years of age or older, you have the right to direct us to not share your personal information at any time (the “right to opt-out”). Our websites and products are not intended for minors. We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization to sell or share (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sharing may opt-out of future sharing at any time.

How to exercise this right:

• By contacting Williams at the toll free number: (888) 700-0096; or
• By sending an email to the following address: [email protected], providing specific details of your request

Do Not Track. We do not track our customers over time and across third party websites to provide targeted advertising and, therefore do not respond to Do Not Track (DNT) signals.

4. The Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA or CPRA rights, and will not engage in the following behaviors:

• Denying you goods or services
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Providing you a different level or quality of goods or services
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
• Retaliating against an employee, applicant for employment, or independent contractor as defined under the CPRA, for exercising their rights under the CPRA.

When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with Williams, such as an email address on file or other methods of verification as allowed under the CCPA and CPRA.

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

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

5. The Right to Correct Inaccurate Personal Information

You shall have the right to request that we correct any inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. If Williams collects your personal information we shall disclose, pursuant to the CPRA, section 1798.130, your right to request correction of inaccurate personal information, which you may do by contacting us at the following email address: [email protected]. Or by calling us at the following toll-free number: (888) 700-0096.

If Williams receives a verifiable consumer request to correct inaccurate personal information, we shall use commercially reasonable efforts to correct the inaccurate personal information, as directed by you pursuant to your rights under the CPRA. We shall also ask any third parties and service providers to whom information has been shared with to correct or delete your personal information upon your request.

6. The Right to Limit Use and Disclosure of Sensitive Personal Information

For purposes of the CPRA, sensitive personal information (“SPI”) includes the following personal information:

• Any communications that you have with a third-party.
  • Williams does not collect any data related to communications you have with a third-party
• Biometric data processed to identity an individual
  • Williams does not collect any biometric data
• Data about sexual orientation or sex life
  • Williams does not collect any information regarding sexual orientation or sex life.
• Financial account details in a combination (e.g. card number and password) that gives or provides access to an account.
  • Williams does not collect any of this data related to financial accounts.
• Genetic data
  • Williams does not collect any genetic data
• Government-issued numbers (such as a social security number or a number on a passport, or driver’s license number).
  • Yes, Williams does collect driver’s license numbers and passport numbers in certain circumstances. Williams also collects SSNs via employer contribution files (Williams’ internal systems utilize alternate IDs in place of SSNs for use in any data transfers).
• Health Data
  • Williams does not collect any health data.
• Philosophical or religious beliefs
  • Williams does not collect any information related to philosophical beliefs.
• Precise geolocation
  • Williams does not collect any data related to precise geolocation.
• Racial or ethnic origin
  • Williams does not collect any data or information related to racial or ethnic origin
• Union membership
  • Williams does collect information about union membership. We keep this data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.

Please note that any information that is already publicly available shall not be considered SPI or personal information.

With regard to any of the data from the above-listed categories which Williams does collect, Williams utilizes the data in furtherance of providing Services to you, and will keep the data for as long as it’s needed to provide Services to you, or as may be required under applicable law, and we will decide to dispose of this data when it is no longer needed to achieve our business-related purposes.

Our use and disclosure of your SPI is limited to those uses which are necessary to perform the Services reasonably expected by an average consumer who requests such Services, including the following Services:

• to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for security and integrity
• To debug to identify and repair errors that impair existing intended functionality
• To perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by Williams, and to improve, upgrade, or enhance the service or device that is owned, manufactured for or controlled by Williams.

Williams only uses SPI to provide the Services.  As such, the use of your SPI is already limited to uses in furtherance of the provision of our Services to you, as we do not use it for other non-Services related purposes.  As such, since use of your SPI is already limited to the provision of the Services to you and not used for any other purpose, your right to limit the use of your SPI to the provision of Services is already attained and exercised.

7. Right Against Automated Decision Making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. We do not foresee that any decisions will be taken about you using automated means, however we will notify you if this position changes.

Authorized Agents

You may authorize a natural person or a business entity registered with the California Secretary of State to act on your behalf to make a request to know or to delete your personal information.

To do so, you must (i) verify your identity to Williams and provide that authorized agent written permission to make such a request or (ii) provide the authorized agent with power of attorney pursuant to the California Probate Code sections 4000 to 4465.

The authorized agent must include those authorizations in the verifiable consumer request.

Security Procedures

Williams shall implement reasonable security procedures and practices appropriate to the nature of the personal information collected about a consumer to protect the personal information from unauthorized or illegal access, destruction, use, modification, or disclosure.

Timeframe for Disclosure

If a consumer requests disclosure of required information, a consumer’s right to request required information beyond a 12-month period, and a business’s obligation to provide such information, shall only apply to personal information collected on or after January 1, 2022.

Children 16 and Under

We do not knowingly collect, solicit, or share personal information from children under the age of 16. If we have knowledge that a child under 16 has submitted personal information in violation of this Policy, we will delete that information as soon as possible. If you believe we may have obtained information in violation of this Policy, please email us at the following address: [email protected], or call at the following toll-free number: (888) 700-0096.

Questions About The CPRA?

If you have questions or concerns regarding this statement, you should first contact us via email at [email protected].

Changes to this Privacy Policy

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. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

California Shine the Light Law

If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail).  You may contact us in two ways. Send an email to [email protected]

Alternatively, you may contact us at:
Williams
250 W LAUREL ST.,
COLTON, CA 92324
Attn:   Your California Privacy Rights
c/o Privacy Administrator

For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email.  All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request.  For all requests, please include your name, street address, city, state, and zip code.  (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile.  We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to the following address: [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Changes in this Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Sites.  Please refer to this policy regularly. If at any time we decide to use personal information in a manner different from that stated at the time it was collected, we will notify you either on the panel homepage of our Sites or via email.

Contact Us

If you have questions or concerns with respect to our Privacy Policy, you may contact us at [email protected].