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LTI California Privacy Policy

This California Privacy Policy is for California residents and supplements our Privacy Policy. This Policy explains how we collect, use, and share your Personal Information and how to exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”). In case of any conflict, the terms of this Policy will prevail as to personal data of California residents that are subject to the CCPA. For purposes of this Policy, the term “personal data” includes all “personal information” as defined in the CCPA.

Please also note that the definition of “personal information” under CCPA is subject to certain exceptions as set forth therein and does not include information that is publicly available or has been aggregated or de-identified in accordance with CCPA or is covered by other relevant legislations such as Health Insurance Portability and Accountability Act (HIPAA), Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and the Drivers Privacy Protection Act (DPPA).

Personal data we collect, use and disclose personal data

In the past 12 months, we have or may have collected the following information about you. Please note that the following list represents categories of personal data across all California residents whose personal data we may have collected or received and does not necessarily represent the information we have collected specifically about you:

Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.Physical location or movements.
Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may have collected and processed personal data for various business purposes in the preceding 12 months, including:

  • Auditing related to interactions with consumers in connection with the professional services LTI provides.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking appropriate action as a result of any such detected activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient uses where the personal data is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the relevant interaction.
  • Performing professional services for our clients.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

We may disclose your personal information to a third party for a business purpose. In the preceding 12 months, we may have disclosed the categories of personal information mentioned in the table above:

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sale of personal data

We do not sell your personal data for monetary consideration. However, we may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other personal data via automated technologies on our website in exchange for non-monetary consideration. We may share the categories of personal data listed below in order to improve the performance of our website, to enhance your browsing experience, to provide you a more personalized browsing experience, and to improve our advertising efforts.You can view a full listing of those third-party cookies and opt-out of their use through the ‘How do I turn off cookies?’ section in our cookie policy.

In the preceding 12 months, we may have sold the following categories of personal data in connection with such third-party cookies:

  • Identifiers. This includes visitors’ internet protocol (“IP”) addresses.
  • Internet or network activity. This includes information about visitors’ interaction with, including information about the visitor’s web browser, page location, referrer, and person using the website; cookie-specific data such as cookie ID and the cookie; and button and field data, such as any buttons clicked by site visitors, the labels of those buttons, any pages visited as a result of the button clicks, and the names of any website fields filled in by visitors.

What Rights Do I Have?
You have the following rights under certain circumstances:

Right of access and data portability

You may have the right to request that we disclose to you information about our collection and use of your personal data in the preceding 12 months, including (a) the categories and specific pieces of personal data we collect; (b) the categories of sources from which we collect or sell personal data; (c) the business or commercial purpose for which we collect personal data; (d) the categories of third parties with whom we share personal data; and (e) the categories of personal data disclosed for a business purpose or sold to third parties and the categories of third parties to whom such personal data was sold or disclosed.

Right to deletion

You may request that we delete certain personal data that we have collected about you. The foregoing is subject to our right to maintain your personal data for specific purposes permitted under CCPA. If we are unable to comply with any such request, we will notify you.

Right to opt-out

You may have the right to request that your personal data not be sold to third parties.

Right to non-discrimination

You have the right to exercise any of the rights listed above (and any other rights under CCPA) without discrimination by us.

Exercising my rights / registering complaints or grievances

You may use any of the following methods to exercise your rights or register any grievance / complaint related to our processing of your personal data or linked to our processing in accordance to applicable data protection principles, our policies, and procedures:

  • Write an email to our Data Protection Officer at
  • Please click here for submitting your requests
  • Call on our local US number +1 732 248 6111 during the work hours. Alternatively, you may call on our US toll-free number +1 833 850 7960;
  • Exercise your right to opt-out of sale via the ‘Do not sell my personal information’ link on our website or directly by opting-out of third-party cookies through the ‘How do I turn off cookies?’ section in our cookie policy.

It should be noted that situations may arise where providing the information requested by you would disclose personal data about another individual. In such cases, information may be redacted or withheld as may be necessary or appropriate to protect that person’s rights.