Request to access your personal information
Thank you for your recent request to know about your personal information – your privacy is very important to us. Provided with this document is a file containing your specific pieces of personal information.
Your personal information file:
Per your verified request, we are providing you a file containing the personal information about you that is subject to the California Consumer Privacy Act (CCPA) amended by the California Privacy Rights Act (CPRA).
Please note the following about your personal information file:
- The amount and type of personal information included in the attached file will vary based on your relationship with Allstate Investments. Based on the personal information about you that we located, it appears that you are an existing or former individual in a commercial relationship with Allstate Investments.
- The way the personal information is presented will vary based on how the information is kept in each system. Some of your information has been redacted or not returned due to risk of fraud such as your social security number, drivers’ license number, financial account number or account passwords. We will let you know that we have collected it but will not provide you with the actual personal information in the response.
- For each piece of personal information returned, we have indicated the category to which that piece of personal information belongs. The categories are listed below with examples of the types of personal information that fall into each category. Those categories allow you to better understand the personal information that is shared and with whom it is shared.
- To protect individual privacy, we only return personal information that we are confident belongs to you. Data that might belong to an individual with a similar name or address will not be returned to you if we aren’t certain it is yours.
To view your personal information, please refer to the attached document titled with your name.
Categories of personal information, sources of personal information, business purposes and third parties:
The following response, together with the information contained in the personal information file, explains the following for the personal information collected:
- The categories of personal information collected;
- The categories of sources from which personal information was collected;
- The business or commercial purpose for collecting personal information;
- The categories of third parties with whom we disclose or share personal information; and
- The categories of personal information disclosed for a business purpose and the category of third parties to whom the personal information was disclosed.
1. The categories of personal information collected:
The file of your personal information shows the category of personal information for each piece of information. These are the categories:
- Personal identifiers to verify identity: We collect personal data to verify your identity such as name, present and former addresses, phone number, and email address;
- Personal characteristics and background: We collect information about your personal characteristics or background for verification purposes such as date of birth, age, nationality, marital status and spouse name, hobbies, personal licenses
- Information to verify suitability for investments: We collect certain documentation that includes personal data to assess and verify suitability for investments including:
- • Passport and other government identification
- • Credit report
- • Bankruptcy records
- • Global media and social media search
- • Adverse and other media
- • Terrorist / sanctions search information
- • Civil records
- • Records of property ownership
- • Criminal records
- • Driving records
- • Motor vehicle or watercraft registrations
- • SEC filings
- • UCC filings
- Professional or employment-related information: We collect personal data to verify employment or professional related information such as current and past employment, membership in professional associations, professional licenses, data collected from a professional or personal reference interview, charitable activities, directorships or other corporate affiliations, and current and past employment;
- Education information: We collect information about your education to verify your education history
- Other background check information: We collect other personal data that may be relevant to your background to verify suitability for investments which may include judgements and liens, regulatory violations or other personal data.
Sensitive personal information
Some personal data we collect is defined under the California Consumer Privacy Act as “sensitive personal information”. Sensitive personal information we collect includes your passport number. This sensitive personal information is only used as reasonably necessary to perform services for internal business purposes that do not require an opt-out of this use. We collect this information for verification purposes but do not retain it longer than needed for purposes of verification.
2. The categories of sources from which personal information was collected
We collect personal information from third party processors such as companies that conduct background checks or directly from you, and this information may be stored digitally or on paper files.
3. The business or commercial purposes for collecting personal information
We use personal information collected from or about you for business purposes including:
- As necessary for the purposes of the Advisers business operations and facilitating investment transactions with the prospective investment partners. The Advisers may collect and use personal data which is necessary for our legitimate interests as investment advisers; for example, to vet and recommend an investment to our clients.
- When we have your consent to do so; and/or
- To comply with legal requirements, including applicable laws and regulations.
4. The categories of third parties with whom we share personal information and the personal information shared with those categories of third parties
We may share any of the categories of personal information described above with any of the following third parties:
- Legal, governmental or regulatory bodies or agencies (including those in the EEA or the US), where required by local law;
- Third parties as required for other legitimate business reasons or as a result of legal or regulatory requirements;
- Third party service providers (known as processors), who hold, use or otherwise process the data on our behalf. This may include storage of data on cloud-based systems. In these circumstances, the Advisers remain responsible for the protection of your data by such third parties;
- If the Advisers are to be sold or if we sell any of the Advisers businesses or assets, we may disclose your personal data to the prospective buyer of the Advisers business or assets. If the Advisers or substantially all of its assets are acquired by a third party, personal data held by it may be one of the transferred assets.
For more information about our privacy practices, please review our Privacy Statement.
Sincerely,
The Allstate Privacy Team