Privacy Policy

Please Note: This is our Website Privacy Policy. For the Cordico App Privacy Policy, please click here.

Published Date: October 27, 2020

This PRIVACY NOTICE is for Cordico, Lexipol and its affiliates and applies to visitors, users, and others who are in the United States (“consumers” or “you”). This notice complies with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, driver’s license, education, employment, employment history. Some personal information included in this category could overlap with other categories.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), sex (including gender, gender identity, veteran or military status.
D. Commercial information.	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a Lexipol website, application, or advertisement, online forums.
G. Geolocation data.	General location.
I. Professional or employment-related information.	Current or past job history, training and certification records.

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following sources:

Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on all our websites and apps. For example, from submissions through our website portal or website usage details collected automatically.
From third parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
From third parties to gather publicly available personal information.

Lexipol respects the privacy of children under the age of eighteen (18). Although users of all ages may navigate through our websites and services, we do not knowingly collect or sell personal information from anyone under age eighteen (18).

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a training roster, we will use that information to prepare the roster and track your completion of training and courses, then submit the information to accrediting agencies as specified by you to us.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that could be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis, and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a normally running business organization or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice.

Sharing Personal Information

We disclose your personal information to a third party for a business purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

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.
Other third parties with whom we share the data for identity verification purposes.
Sponsors.
Advertising networks and social media networks. Advertising networks and social media network providers use cookies and similar technologies to collect information about your interaction with the services. To learn more about our use of cookies and similar technologies, please read our “Cookie Notice.”

Sale of Personal Information

We sell your personal information to a third party for a business purpose. In the preceding twelve (12) months, we have sold the following categories of personal information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

We sell your personal information to the following categories of third parties:

Sponsors with whom we share personal data based as per lead forms submitted by you.
Other third parties with whom we share the data for identity verification purposes.
Advertising networks and social media networks. Advertising networks and social media network providers use cookies and similar technologies to collect information about your interaction with the services. To learn more about our use of cookies and similar technologies, please read our “Cookie Notice.”

To stop the sale of your personal information, you can submit a request via the Do Not Sell My Info link.

Your Rights and Choices Under CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by:

Emailing us at privacy@lexipol.com or by calling us toll-free at 844-312-9500.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, can make a verifiable consumer request related to your personal information.

You can only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You can also submit a request via the Do Not Sell My Info link.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you could receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this privacy notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:
privacy@lexipol.com
844-312-9500