California Privacy Policy

This California Privacy Policy supplements the information contained in our Privacy Policy and Client Data Privacy Notice (“Privacy Notice”) (together, “Privacy Statements”) and is adopted to comply with the California Consumer Privacy Act (including the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). This California Privacy Policy (“CCPA Policy”) applies solely to visitors, users, Clients, and/or others who reside in the State of California (“consumers”). Any terms defined in the CCPA have the same meaning when used in this CCPA Policy. All other capitalized terms shall have the same meaning as those designated in the Privacy Statements. This CCPA Policy explains how CohnReznick LLP, and certain of its affiliates, (“CohnReznick,” “we,” “us,” or “our”) collect, use, disclose and retain Personal Information and how consumers may exercise their rights under CCPA.

WHAT INFORMATION IS COLLECTED 

The CCPA defines Personal Information as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” but does not include certain exempt information, publicly available information, or deidentified or aggregated information. CohnReznick’s data collection practices include the collection and use of Personal Information as described in the Privacy Statements and as set forth below. This CCPA Policy applies to our data practices both online and offline. CohnReznick retains this information as set forth in the Privacy Statements. (See, Retention of Personal Information).

Generally, CohnReznick collects the following categories of Personal Information:

• Identifiers, including contact information and biographic information;
• Commercial information;
• Financial information;
• Internet or other similar network, browsing, or search activity;
• Non-precise Geolocation data;
• Professional or employment-related information; and
• Sensitive personal information

OUR PURPOSES FOR THE COLLECTION AND USE OF PERSONAL INFORMATION

Our collection of Personal Information is limited to the business and commercial purposes as described below:

1. For execution of a Contract, to execute our rights or the rights of our service providers under a Contract, or enforce the terms and conditions arising under a Contract (e.g., performing services, maintaining the client relationship, keeping the client informed, invoicing and bill collection) or other agreement between the parties;
2. To perform client acceptance procedures, including verifying identities and addresses and performing other due diligence to protect our business interests and to determine eligibility for services;
3. To comply with legal, tax, accounting, or regulatory obligations to which CohnReznick or a third party is subject, including complying with auditing standards;
4. To manage risk and operations, legal obligations, including ensuring internal compliance with our policies and procedures, to respond to regulatory and government oversight applicable to CohnReznick, and to investigate complaints or pursue and defend claims, proceedings, or disputes;
5. To protect the security and integrity of CohnReznick’s information technology systems;
6. To provide information about relevant services offered by CohnReznick, opportunities and experiences offered by CohnReznick and relevant developments in the marketplace and industry;
7. To evaluate, develop and improve the quality of CohnReznick’s professionals and services or our website and for other related internal business purposes;
8. To seek professional advice, such as from professional advisors (including, but not limited to, legal counsel);
9. To recruit and evaluate qualifications for employment or internships;
10. For website related services, like analytics, insights, or customer support, quality and safety maintenance, or to develop new technological improvements;
11. For other purposes that are compatible with this Privacy Policy or where permitted by applicable law; and
12. As otherwise disclosed upon collection, or to the extent Client or a data subject provides other consent or authorization to the collection, use, disclosure and storage of personal information.

SOURCES OF COLLECTION OF PERSONAL INFORMATION 

We may collect Personal Information from the following sources:

• From a Client;
• Directly from You when you fill out an application for employment or sign a Contract for services with CohnReznick;
• From users of our website, both directly and through automatic means;
• From forms, webinars, surveys, tradeshows, and other information You provide us; 
• From certain affiliates, business partners or agents;
• If You provide us with information when contacting us, request information about our services, or contact our customer service or support departments via phone, email, chat or other forms of communication;
• Fraud prevention and detection agencies and organizations, including law enforcement;
• From third party sources, including publicly available sources and governmental agencies and departments; and
• Through engagement with our social media platforms.

The chart below describes the categories of Personal Information collected in the previous twelve months and the business or commercial purposes for such collection. For more information about the exact identifiers we collect, please see our general privacy policy above and the section labeled “What information is collected.” The numbers below align with the “Our Purposes for Collection and Use of Personal Information” section outlined above.

CATEGORIES OF THIRD PARTIES WITH WHOM WE DISCLOSE PERSONAL INFORMATION

We disclose the categories of Personal Information outlined above to certain service providers or other third parties for business purposes, to provide our products and services, or for other purposes as provided by CCPA. This includes to:

a)  professional service providers for business operations or provision of services;

b) information technology, software, and cloud providers, security providers, and similar services in connection with providing services and in the support of daily operations;

c)  service providers to support business operations;

d)  service providers to develop, operate, and maintain our website;

e) service providers for marketing purposes;

f) our employees, affiliated companies, contractors, agents and third-party vendors to perform services related to your account, to offer our products and services, and for business operations.

We may also have to disclose your information to:

a) government agencies or regulatory bodies to fulfill legal obligations;

b) a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including potentially as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred;

c) law enforcement or government officials;

d) any other entity disclosed by CohnReznick when you provide the information, or for which you provide authorization; or

(e) third party fraud prevention and credit risk reduction companies and organizations.

“SELLING” OR “SHARING” OF PERSONAL INFORMATION

CohnReznick may “share” your Personal Information, as defined under CCPA, to marketing software providers to use for cross-contextual behavioral advertising. The categories of Personal Information shared include your identifiers, commercial information, internet and other electronic identifiers, and inference information.

CohnReznick does not have actual knowledge that it shares Personal Information of consumers under the age of 16. If you are between 13 and 16 years of age, you must authorize us to sell or share your Personal Information. If you are under 13 years of age, your parent or guardian must authorize us to sell or share your Personal Information.

You have a Right to Opt-Out of the sharing of your Personal Information by us at any time. You can submit a request to opt out of the sale or sharing of your Personal Information through the other methods referenced below in this Policy. The Right to Opt-Out is subject to exemptions under the CCPA and other limitations under applicable law.

CONSUMER RIGHTS UNDER CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section explains how those rights may be exercised.

1. Consumers have the right to request to certain information about our collection and use of Personal Information (the “Right to Know”) or access to specific pieces of personal information (“Specific Request to Know”). Consumers may only submit two requests per a twelve-month period, beginning on the date of their first request.
2. Consumers have the right to request correction of inaccurate Personal Information (“Right to Correct”) maintained by CohnReznick.
3. Consumers have the right to opt-out of the sale or sharing of personal information (“Right to Opt-Out”).
4. Consumers have the right to request deletion of Personal Information, subject to certain exceptions (the “Right to Delete”). Once we receive a request and confirm the consumer’s identity we will review the request to determine if an exception allowing us to retain the information applies. We may deny a deletion request if retaining the Personal Information is necessary for us to:
   • Complete the transaction(s) for which we collected the Personal Information including to provide requested services requested or otherwise to fulfill our contractual obligations; and/or
   • As otherwise allowed by the CCPA.
5. We will not discriminate against consumers for exercising CCPA rights including refusing Services or offering different pricing models.

SHINE THE LIGHT

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits CohnReznick’s clients who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once each calendar year and are free of charge. You may make a request for this information by contacting us using any of the below methods.

HOW TO EXERCISE RIGHTS UNDER CCPA

California consumers or authorized agents may submit a request in one of the following ways:

1. By emailing us at [email protected]  
2. By telephone at: 1- 862-245-5031
3. By submission of a Privacy Request Web Form: Privacy Request Web Form
4. By written notice mailed to: 

   CohnReznick LLP
   Attn: Legal Department
   14 Sylvan Way
   Parsippany, New Jersey 07054

Updates to this CCPA Policy

Please refer to this CCPA Policy regularly as it may be revised due to legislative changes, changes in technology or our privacy practices or new uses of customer information not previously disclosed in this CCPA Policy. Changes to this Policy are effective when they are posted on this page. If you have any comments, concerns, or questions about this CCPA Policy, please contact us through one of the methods set forth above.