California Consumer Privacy Act Disclosure

Revision Date: January 1, 2023

Applicability

This California Consumer Privacy Act Disclosure explains how Highland Associates (“Company,” “we,” or “us”) collect, use, disclose, sell, share, and retain personal information relating to California residents covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”). This notice is provided pursuant to the CCPA. Highland Associates is an affiliated company of Regions Bank (see http://www.regions.com).

Introduction

Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. 

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.

Collection and Disclosure of Personal Information

In the past 12 months, we have collected, and disclosed to third parties for our business or commercial purposes, the following categories of Personal Information relating to California residents covered by this disclosure:

  • Identifiers, such as name and email address;
  • Internet or network activity information, such as browsing history and interactions with our website;
  • Geolocation data, such as device location and Internet Protocol (IP) location; and
  • Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.

Highland Associates does not collect Sensitive Personal Information (e.g., Social Security, driver’s license, state identification card, or passport number), as defined by California law. 

The categories of sources from whom we collected this Personal Information are:

  • Directly from a California resident (or the individual’s representatives) visiting our website; and
  • Website Activity

The categories of third parties to whom we disclosed Personal Information for our business or commercial purposes described in this privacy disclosure are:

  • Affiliates (Highland Associates is an affiliated company of Regions Bank)
  • Vendors and Service Providers who provide services such as website hosting, data analysis, information technology and related infrastructure, customer service, and email delivery
  • Partners and Third Parties who provide services such as communication infrastructure, storage, and legal expertise
  • Government Agencies as required by laws and regulations

Business or Commercial Purpose of Collecting and Disclosing Personal Information

In the past 12 months, we have collected and disclosed Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business and commercial purposes and objectives, including the following:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, providing storage, or providing similar services.
  • Helping to ensure security and integrity where the personal information is reasonably necessary and proportionate for these purposes.
  • Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction.
  • Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Undertaking internal research for technological development and demonstration.
  • As part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.
  • To advance our commercial or economic interests.
  • Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)

Sale and Sharing of Personal Information and Disclosure of Sensitive Personal Information

Highland Associates does not “sell” or “share” Personal Information subject to the CCPA, including Personal Information of minors under the age of 16, nor do we intend to do so in the future. We do not and will not sell or share your personal information.  For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration, and “shared” means the disclosure of Personal Information to a third-party for cross contextual behavioral advertising.

How Long We Retain Your Personal Information

We store personal information for as long as we believe is reasonably necessary or appropriate to fulfill our business purposes or to comply with applicable law, audit requirements, regulatory requests, or orders from competent courts.

Rights under the CCPA

If you are a California resident, you have the right to:

  • Know at or before the time of collection:
    • The categories of personal information to be collected, the purposes for which the categories of personal information are collected or sued, and whether that information is sold or shared;
    • The categories of sensitive personal information to be collected, the purposes for which the categories of sensitive personal information are collected or sued, and whether that information is sold or shared; and
    • The length of time the business intends to retain each category of personal information, including sensitive personal information.
  • Request we disclose to you free of charge the following information collected and maintained since January 1, 2022:
    • the categories of Personal Information about you that we collected;
    • the categories of sources from which the Personal Information was collected;
    • the business or commercial purpose for collecting Personal Information about you;
    • the categories of personal information that we disclosed about you for a business or commercial purpose
    • the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable); and
    • the specific pieces of Personal Information we collected about you
  • Request we delete Personal Information we collected from you or your household, unless the CCPA recognizes an exception
  • Request we correct any inaccurate personal information that we have collected from you and/or maintained about you; and
  • Be free from unlawful discrimination and retaliation for exercising your rights under the CCPA
  • You also have the right to opt out of the sale/sharing of your Personal Information and to limit the use or disclosure of any Sensitive Personal Information. Regions does not sell or share Personal Information or use or disclose any Sensitive Personal Information other than as allowed by the CCPA and its implementing regulations.

We will acknowledge receipt of your request within 10 business days and advise you how long we expect it will take to respond if we are able to verify your identity. We will verify your identity by matching the information you provide us with information in our systems. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account and we will also require you to re-authenticate yourself before we disclose your personal information. Requests for specific pieces of Personal Information will require additional information to verify your identity. We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by law.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access, correction, or deletion rights.

We will advise you in our response if we are not able to honor your request and the reasons why. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information.

We will work to process all verified requests within 45 calendar days pursuant to the CCPA. If we need an extension for up to an additional 45 calendar days in order to process your request, we will provide you with an explanation for the delay.

How to Exercise Your Rights

If you are a California resident, you may submit a request by:

  • Completing an online Data Request Form
  • For yourself: Access the request form here.
  • On behalf of another individual (representatives should access the request form here).

We have engaged DocuSign as our service provider to process Data Subject Access Requests (DSAR). DSAR email communications will be provided by DocuSign on behalf of Regions Bank on behalf of Highland Associates.

Contact us at 1-800-986-2462

Questions or Concerns

For further information about this disclosure or our practices, please call 1-800-986-2462 or email us at PrivacyCompliance@regions.com.

Change Notice

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new revision date.