California Privacy Policy

Effective Date: January 12, 2024

This Privacy Policy for California Residents supplements the information contained in the Website Privacy Policy of LHP, Inc. and its affiliates and subsidiaries (LHP Engineering Solutions LLC, LHP Data Analytic Solutions LLC, and DAXEOS LLC) (“we” or “us”) Privacy Policy 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 the California Privacy Rights Act of 2020 (CPRA). Any terms defined in the CCPA and the CPRA have the same meaning when used in this Privacy Policy for California Residents.

Information We Collect

We collect 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”). Personal information does not include publicly available information from government records, and deidentified or aggregated consumer information.

We have collected the following categories of personal information from consumers within the last 12 months:

Category	Description	Source	Business Purpose for Collection
Identifiers	Real name, alias, home/postal/mailing address, telephone number, email address, Social Security number, driver's license number, state identification card number, passport number, unique personal identifier, online identifier, Internet Protocol address or other similar identifiers.	Consumers; service providers; consumers’ online activity (through tracking technologies including cookies, web beacons, flash cookies and analytic tools); social media sites (Facebook, Twitter, LinkedIn; YouTube); parent company, subsidiaries and affiliates.	Performing services; quality and safety maintenance and verification; auditing interactions with consumers; security; debugging and repair; internal research for technological development.
Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(a))	Signature, education information/history, employment information/history, bank account number, credit card number, debit card number or any other financial information, medical information, or health insurance information.	Consumers; service providers.	Performing services.
Characteristics of protected classifications under state or federal law	Race, national origin, gender, age, sexual orientation, medical conditions, disability, military or veteran status, request for family and medical care leave, and request for pregnancy disability leave.	Consumers; service providers; parent company, subsidiaries and affiliates.	Performing services.
Other personal information	Insurance policy numbers, date of birth, marital status/sexual orientation, income, racial or ethnic group.	Consumers; service providers; parent company, subsidiaries and affiliates.	Performing services.
Internet or other similar network activity	Browsing, search history, and information regarding your interaction with an internet website application, or advertisement.	Consumers’ online activity (through tracking technologies including cookies, web beacons, flash cookies and analytic tools).	Quality and safety maintenance and verification; auditing interactions with consumers; security; debugging and repair; internal research for technological development.
Geolocation data	Location of company-issued laptops, mobile phones or other electronic devices.	Consumers.	Performing services; quality and safety maintenance and verification; security.
Sensory data	Audio, electric, visual, thermal, olfactory or similar information.	Consumers; consumers’ online activity (through tracking technologies including cookies, web beacons, flash cookies and analytic tools).	Quality and safety maintenance and verification; auditing interactions with consumers; security; debugging and repair; internal research for technological development.
Professional or employment history information	Work history, prior employer, human resources data, and data necessary for administering benefits or related administrative services.	Consumers; service providers; parent company, subsidiaries and affiliates.	Performing services.
Non-publicly available educational information	Grade point average, report card and school transcript.	Consumers; service providers; parent company, subsidiaries and affiliates.	Performing services.
Commercial information	Products or services purchased or obtained.	Consumers; service providers; parent company, subsidiaries and affiliates.	Performing services; auditing interactions with consumers; internal research for technological development.
Unique personal identifiers	Device identifier, online identifier, cookies, flash cookies, beacons, pixel tags, mobile ad identifiers, account name, customer number.	Consumers’ online activity (through tracking technologies including cookies, web beacons, flash cookies and analytic tools).	Quality and safety maintenance and verification; auditing interactions with consumers; security; debugging and repair; internal research for technological development.

We will not collect additional categories of personal information for materially, different, unrelated, or incompatible purposes without providing you notice.

We will retain personal information for as long as we deem reasonably necessary to achieve the purposes for which the personal information was collected.

Use of Personal Information

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

To fulfill the purpose for which you provided the information.
To provide, support, personalize, develop, and improve our website, products, and services.
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 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 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 a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described when collecting your personal information or as otherwise set forth under the CCPA and the CPRA.

We will not use the personal information we collected for materially, different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party (including service providers) for a business purpose. We only make these business purpose disclosures to third parties under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

In the last 12 months we have disclosed personal information for a business purpose to the categories of third parties indicated below.

Category	Description	Categories of Third Parties
Personal identifiers	Real name, alias, home/postal/mailing address, telephone number, email address, Social Security number, driver's license number, state identification card number, passport number, unique personal identifier, online identifier, Internet Protocol address or other similar identifiers.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(a))	Signature, education information/history, employment information/history, bank account number, credit card number, debit card number or any other financial information, medical information, or health insurance information.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Characteristics of protected classifications under state or federal law	Race, national origin, gender, age, sexual orientation, medical conditions, disability, military or veteran status, request for family and medical care leave, and request for pregnancy disability leave.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Other personal information	Insurance policy numbers, date of birth, marital status/sexual orientation, income, racial or ethnic group.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Internet or other similar network activity	Browsing, search history, and information regarding your interaction with an internet website application, or advertisement.	Service providers; and parent company, subsidiaries and affiliates.
Geolocation data	Location of company issued laptops, mobile phones or other electronic devices.	Parent company, subsidiaries and affiliates.
Sensory data	Audio, electric, visual, thermal, olfactory or similar information.	Parent company, subsidiaries and affiliates.
Professional or employment history information	Work history, prior employer, human resources data, and data necessary for administering benefits or related administrative services.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Non-publicly available educational information	Grade point average, report card and school transcript.	Service providers; government entities; and parent company, subsidiaries and affiliates.
Commercial information	Products or services purchased or obtained.	Service providers; and parent company, subsidiaries and affiliates.
Unique personal identifiers	Device identifier, online identifier, cookies, flash cookies, beacons, pixel tags, mobile ad identifiers, account name, customer number.	Service providers; and parent company, subsidiaries and affiliates.

We do not sell, rent, release, disclose, disseminate, make available, transfer or lease your personal information to third parties for monetary value or other valuable consideration, and have not done so in the past 12 months.

We may share, rent, release, disclose, disseminate, make accessible or transfer your personal information to third parties for cross-cultural behavioral advertising or promotional purposes. In the past 12 months we have not shared, rented, released, disclosed, disseminated, made accessible or transferred your personal information to third parties for cross-cultural behavioral advertising or promotional purposes.

Your Rights and Choices

The CCPA and the CPRA provide consumers with specific rights regarding their personal information. This section explains your CCPA and CPRA rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you: (a) the categories of personal information we collected about you; (b) the specific pieces of personal information we collected about you; (c) the categories of personal information we have disclosed to third parties; (d) the specific pieces of personal information we have disclosed to third parties; (e) the categories of sources for the personal information we collected about you; (f) our business purpose for collecting personal information about you; and (g) the categories of third parties with whom we have disclosed your personal information. For disclosure of personal information for a business purpose, we also will identify the personal information categories that each category of recipient obtained.

You may only submit a request to know twice within a 12-month period.

Right to Delete

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, 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 providers to: (a) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, disruptive, fraudulent or illegal activity, or prosecute those responsible for such activities; (c) help ensure security and integrity to the extent that the use of your personal information is reasonably necessary and proportionate for those purposes; (d) debug products to identify and repair errors that impact existing intended functionality; (e) exercise free speech, ensure the right of other consumers to exercise their free speech rights, or exercise another right provided by law; (f) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.); (g) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) comply with a legal obligation; and (i) make other internal and lawful uses of your personal information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. We will maintain a record of your deletion request for at least 24 months or as otherwise needed to ensure that your personal information remains deleted from our records.

In our response to your request, we will specify the manner in which we have deleted your personal information or, if we must deny your deletion request, the basis for this denial.

Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information that we have collected from you. Once we receive your request and confirm your identity, we will review your request to see if an exception applies to your request.

We will correct your personal information and will direct our service providers to take similar action.

In our response to your request, we will specify the corrections made to your personal information or, if we must deny your correction request, the basis for this denial.

Right to Opt-Out of Sharing of Your Personal Information

You have the right to opt-out or ask us not to share your personal information with third parties for cross-cultural behavioral advertising or promotional purposes. To exercise this right, please click the DO NOT SHARE MY PERSONAL INFORMATION button below.

You may also exercise your right to opt-out or ask us not share your personal information with third parties for cross-cultural behavioral advertising or promotional purposes by emailing us at california.privacy@lhpes.com. If you email your request, please provide the following information: (a) first name; (b) last name; (c) email address; (d) telephone number; and (e) address (including street name and number, city, state, and zip code or postal code).

You do not need to create an account with us to exercise your right to opt-out or ask us not share your personal information with third parties for cross-cultural behavioral advertising or promotional purposes.

We will only use personal information provided when you exercise your right to opt-out or ask us not share your personal information with third parties for cross-cultural behavioral advertising or promotional purposes to verify your identity or authority to exercise your right.

We will confirm the receipt of your request to opt-out from the sharing your personal information with third parties for cross-cultural behavioral advertising or promotional purposes within 10 business days. If you do not receive confirmation within the 10-day timeframe, please call us toll free at 877-283-8808 or email us at california.privacy@lhpes.com.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your privacy rights. Unless permitted by the CCPA and CPRA, 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; and (d) suggest that you receive a different price or rate for goods or services or a different level or quality of goods and services.

Exercising Your Rights to Know, Delete, or Correct Your Personal Information

To exercise your rights to know, delete, or correct your personal information, please submit a verifiable consumer request by calling us toll-free at 877-283-8808 or emailing us at california.privacy@lhpes.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct your personal information. To designate an authorized agent to submit a request to know, delete, or correct your personal information on your behalf, your authorized agent must provide to us a valid Power of Attorney under the California Probate Code, or evidence that your authorized agent has your written permission to submit your request to know, delete, or correct your personal information accompanied by an Authorized Agent Designation Form. Our Authorized Agent Designation Form can be obtained by calling us toll free at 877-283-8808 or emailing us at california.privacy@lhpes.com. Please email the completed Authorized Agent Designation Form to california.privacy@lhpes.com.

You may make a request to know, delete, or correct personal information on behalf of your child by calling us toll free at 877-283-8808 or emailing us at california.privacy@lhpes.com.

We cannot respond to your request to know, delete, or correct your personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Your request to know, delete, or correct your personal information must provide sufficient information to allows us to reasonably verify that you are the person about whom we collected personal information. To verify your identity, we ask that you provide us with the following information when you submit your request: (a) first name; (b) last name; (c) email address; (d) telephone number; and (e) address (including street name and number, city, state, and zip code or postal code). We may require additional information to verify your identity and respond to your request depending on the type of request or the information requested by you. You do not need to create an account with us to submit a request to know, delete, or correct your personal information. We will only use personal information provided in the request to know, delete, or correct your personal information to verify your identity or authority to make the request.

Your request to know, delete, or correct your personal information must describe your request with sufficient detail to allow us to properly understand, evaluate and respond to it.

We will confirm the receipt of your request to know, delete, or correct your personal information within 10 business days. If you do not receive confirmation within the 10-day timeframe, please call us toll free at 877-283-8808 or email us at california.privacy@lhpes.com.

We make every effort to substantially respond to a request to know, delete, or correct personal information within 45 days of its receipt. If necessary, we may need an additional period of time (up to another 45 days) but will provide you with the reason for the extension and the extension period in writing.

We will deliver our written response by mail or email, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of your request to know, delete, or correct your personal information.

The response we provide will also explain the reasons why we cannot comply with your request to know, delete, or correct your personal information, if applicable.

We do not charge a fee to process or respond to your verifiable request to know, delete, or correct your personal information, unless your request is excessive, repetitive, or manifestly unfounded. If we determine that your request know, delete, or correct your personal information warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing our response.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on our 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 Information

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

Phone: 877-283-8808

Email: california.privacy@lhpes.com

Postal Address: LHP, Inc., Attn: Legal Department, 305 Franklin Street, Columbus, Indiana 47201