PRIVACY NOTICE SUPPLEMENT – CALIFORNIA RESIDENTS

Purpose and Application

This Supplement was adopted to comply with the 2018 California Consumer Privacy Act (“CCPA”) and is to be read in conjunction with the information contained in the standard Privacy Notice of WEDGE Capital Management L.L.P. This Supplement applies solely to individuals interacting with WEDGE who reside in the State of California. 

Personal Information Defined

Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household. Personal Information includes, but is not limited to, the following: (a) identifiers, (b) select information in consumer records, (c) legally protected characteristics, (d) commercial purchasing information, (e) biometric information, (f) internet or network activity, (g) geolocation, (h) information typically detected by the senses, (i) employment information, (j) education information, or (k) inferences from the above categories used to profile. Personal Information does not include the following: (a) publicly available information from government records, (b) de-identified or aggregated consumer information, (c) information excluded from the CCPA’s scope such as 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, or(d) personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information

We may use or disclose personal information we collect for one or more of the following business purposes (a) fulfill the purpose we stated when you provided us the information, (b) provide you with information, products or services that you request from us, (c) provide you with email alerts (d) carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billings and collections, (e) improve our website and present its contents to you, (f) testing, research, analysis and product development, (g) as necessary or appropriate to protect the rights, property or safety of us, our clients and others, (h) respond to law enforcement requests and as required by applicable law, court order or governmental regulations or (i) as described to you when collecting your personal information or as otherwise set forth in the CCPA.

Collection and Sharing of Personal Information

WEDGE does not “sell” Personal Information and has not “sold” Personal Information relating to you, including within the meaning of the CCPA within the past 12 months. For purposes of this disclosure, “sell” or “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration. We may collect and store different kinds of Personal Information about you for business purposes depending on our relationship or interaction with you. 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. We source Personal Information directly from our clients or their agents. Except under the limited circumstances outlined in our standard Privacy Notice, we do not intend to share Personal Information with nonaffiliated third parties.

Your Rights

Under the CCPA, you have specific rights regarding your Personal Information held by private companies. The following sections describe your rights and how to exercise them.

Disclosure

You have the right to ask us to disclose to you any Personal Information we have collected about you in the last 12 months. To exercise this right, WEDGE must verify your identity to ensure it is a legitimate request before disclosing to you the following: (a) the categories of Personal Information we have collected about you, (b) the types of sources used to collect Personal Information about you (c) if applicable, the types of third parties with which we have shared any of your Personal Information, (d) the business or commercial purpose for collecting your Personal Information, (e) the specific pieces of Personal Information we collected about you (also called a data portability request), (f) the categories of Personal Information that have been disclosed for a business purpose that each category of recipient obtained.

Deletion

You have the right to request that we delete the Personal Information we have collected from and about you. To exercise this right, WEDGE must verify your identity to ensure it is a legitimate request before deleting the relevant information, unless an exemption applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to: (a) provide a good or service that you requested, (b) take actions reasonably anticipated within the context of our ongoing business relationship with you, (c) otherwise perform our contract with you, (d) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us, (e) comply with a legal obligation, (f) detect security incidents, protect against malicious deceptive, fraudulent or illegal activity or prosecute those responsible for such activity, (g) debug products to identify and repair errors that impair existing intended functionality, (h) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law, (i) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Sec. 1546 seq), or (j) 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.

Non-Discrimination

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Exercise of Rights

To exercise the access, data portability, or deletion rights described above please submit a verifiable consumer request via the contact information noted in our standard Privacy Notice. 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. If an authorized agent submits a request on your behalf, you may be asked to verify your identity directly with WEDGE. 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 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. Making a verifiable consumer request does not require you to create an account 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.

Right to Opt Out of Sharing of Personal Data

Subject to certain exceptions, you may have the right to opt out of our sharing your personal data.

Right to Correct Inaccurate Personal Information

If you believe that personal information that we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Limit Use and Disclosure of Sensitive Information

You have the right to request that we limit the use of your sensitive personal information to uses which are necessary to perform the services or provide the goods as requested, as authorized by regulations, or as otherwise permitted by the CCPA.

Response Timing and Format

We endeavor to respond to a verifiable consumer request as soon as practicable. 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 using the contact information we have on file for that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 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. 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.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at any time. When we make changes to this privacy notice, we will post the changes here.