Effective October 1, 2020
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) addresses how City National Rochdale and its subsidiaries (collectively “we”, “us”, “our,” or “CNR”) collect, use, and share “Personal Information” as defined in the California Consumer Privacy Act (“CCPA”). This CCPA Disclosure supplements all other CNR privacy policies and notices applicable to CNR services and applies solely to California residents. Any capitalized terms used in this policy have the same meaning as in the CCPA unless otherwise defined.
Information covered under the CCPA
As used in this CCPA Disclosure, Personal Information means any 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. Personal Information does not include: (i) publicly available information from government records; (ii) de-identified or aggregated consumer information; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA) and the Gramm-Leach-Bliley Act (GLBA).
What categories of information does CNR collect?
We have collected the following categories of Personal Information from consumers within the preceding twelve (12) months:
|Identifiers||Names, address, email address, Social Security number, online identifiers, internet protocol address, or other similar identifiers|
|Personal information as defined in the California Customer Records Act, Cal. Civ. Code § 1798.80||Contact and financial information|
|Protected classifications under California or federal law||Age, marital status, sex, and veteran or military status|
|Commercial information||Information about past transactions or purchases|
|Biometric information||Voiceprints and behavioral characteristics derived from interactions with our websites or mobile apps|
|Internet or similar network activity information||Browsing history, search history, information about a consumer’s interaction with a website, application, or advertisement|
|Geolocation data||Device location|
|Audio, electronic, visual, or similar information||Call and video recordings|
|Inferences drawn from other personal information||Certain inferences concerning an individual’s preferences and characteristics|
HOW DOES CNR COLLECT THESE CATEGORIES OF PERSONAL INFORMATION?
CNR collects the Personal Information above from the following categories of sources:
- Directly from consumers
- Service Providers
- Publicly available sources and registries
- CNR affiliates
- Business partners
- Third parties authorized to share information with us
- Government entities
WHY DOES CNR COLLECT THESE CATEGORIES OF PERSONAL INFORMATION?
CNR uses the Personal Information above for the following purposes:
- Providing products and services to consumers
- Identifying and preventing fraud
- Verifying your identity
- Conducting data analysis and research
- Improving products and services
- Marketing and advertising
- Maintaining internal systems and infrastructure
- Ensuring compliance with all other applicable laws and regulations
- Responding to civil, criminal, or regulatory requests
- For any other use disclosed at or before the point of collecting the Personal Information
CNR may also use the Personal Information referenced above for any one of the specific “business purposes” described in the CCPA:
- Auditing related to a current interaction with the consumer
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Identifying and debugging errors that impair functionality
- Permissible short-term transient use
WHO DOES CNR SHARE PERSONAL INFORMATION WITH?
CNR shares the Personal Information above with the following parties:
- Our parent companies – Royal Bank of Canada (“RBC”) and City National Bank (“CNB”)
- Business partners
- Service providers
- Third parties with whom you authorize or direct us to share your information
- Government entities and others with whom we share information for legal or necessary purposes
DOES CNR SELL ANY PERSONAL INFORMATION?
CCPA CONSUMER RIGHTS
The CCPA also provides California consumers with certain additional rights regarding their Personal Information.
Right to Access
You have the right to request that we disclose the categories of Personal Information CNR has collected about you in the preceding twelve-month period. We must also provide you with a summary of the purposes for which the categories of Personal Information were collected.
Once you submit an access request, you may also separately request a portable copy of the specific pieces of Personal Information CNR has collected about you (subject to heightened verification).
We will disclose the applicable information specified above to you upon receipt of your verifiable consumer request (see “Submitting a Verifiable Consumer Request” section below).
Right to Deletion
You have the right to request that we delete any of your Personal Information subject to the various exceptions provided in the CCPA (see “Submitting a Verifiable Consumer Request” section below).
Submitting a Verifiable Consumer Request
In order to protect your information, we can only honor access or deletion requests upon receipt of a verifiable consumer request. Your request must provide information that enables us to verify your identity in order for us to respond.
You agree to respond to any reasonable requests from us for additional information to enable us to verify your identity in connection with your access or deletion requests.
You may submit a verifiable consumer request by:
- Contacting us by telephone at (800) 773-7100 from Monday through Friday between 8:00 a.m. and 4:30 p.m. PT or emailing CompliancePrivacy@cnb.com Upon receiving a request, we will attempt to verify your identity and will respond within no more than forty-five days as required by the CCPA.
Once you have submitted a valid data access request, you will be issued a reference number which may then be used to submit either a deletion or specific information request (subject to heightened verification). For either of these data requests, simply email your data access reference number and the type of request to CompliancePrivacy@cnb.com.
RIGHT TO NONDISCRIMINATION
We will not discriminate against you because you elect to exercise any of your rights under the CCPA including, but not limited to:
- Denying goods or services to you
- Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties on you
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
None of the foregoing, however, prohibits us from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to us by your data.