Brighton Jones Companies and the California Consumer Privacy Act (CCPA)

Depending on whether you have a relationship or otherwise interact with Brighton Jones, LLC or one of its affiliated companies, the nature of your relationship and interactions with that Brighton Jones company will determine whether the personal information that the Brighton Jones company collects or maintains is covered by one or more of the exemptions described below (see the section below entitled “CCPA Exemptions”). As a result, in some cases, the applicable Brighton Jones company may have no obligation under the CCPA to accept any CCPA requests, and in other cases, it may have no obligation to honor a particular CCPA request, because of the nature of the personal information that the Brighton Jones company collects or maintains. Here is an example of a CCPA exemption:

If you participate in a workplace retirement plan, or other employee benefit plan sponsored by or provided through your employer, that is serviced or administered by a Brighton Jones company, CCPA requests should be directed to your employer.

Your Rights Under the CCPA

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. As used below, a “consumer” means a resident of the State of California and a “covered business” means a business that is subject to the CCPA.

Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the following:

  • The categories of personal information it has collected about that consumer
  • The categories of sources from which the personal information is collected
  • The business or commercial purpose for collecting, selling or sharing (if applicable) personal information
  • The categories of third parties to whom the covered business discloses personal information
  • The specific pieces of personal information that the covered business has collected about that consumer

These disclosures are not required to include any information about activity that occurred prior to January 1, 2022. Please also note that a covered business is not required to honor more than 2 of these requests from the same consumer during any 12-month period.

Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.

Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.

Right to Opt-Out of Sale/Sharing. If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business.

CCPA Exemptions

Please note that certain types of personal information collected or maintained by a covered business are exempt from the CCPA. For example, a covered business has limited obligations, or in some cases, no obligations, under the CCPA with regard to the following types of personal information:

  • Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code)
  • Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.

Please note that the description of the CCPA set forth in this privacy notice is a summary of only certain aspects of the CCPA and is not and should not be considered a complete description of the CCPA. In addition to what is described above, the CCPA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer’s personal information.

Submitting a CCPA Request

If you wish to submit a CCPA request to any of the Brighton Jones companies listed in the main Brighton Jones privacy notice, you may initiate your request by contacting Brighton Jones by emailing compliance@brightonjones.com or calling (206) 258-5000. Before submitting your request, please ensure you have reviewed all the CCPA exemptions, including those described above under the section above entitled “CCPA Exemptions”.

You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.

We will need to verify your identity before we can process your request. Through the request process, we will make you aware of any information that you will need to provide to us to process your request. You may have to confirm that you are a California resident and verify your identity or the identities of those authorized to submit requests on your behalf. Additionally, the information you provide will be used to help verify your identity.