Privacy Policy

EFFECTIVE DATE: JULY 1, 2023

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Champlain Investment Partners, LLC (collectively, “we,” “us,” or “our”). The purpose of this supplemental privacy notice is to provide additional details about our information practices to California residents (collectively, “consumer,” “you,” or “your”) and inform you of your rights required by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (collectively, “CPRA”).

Notice of Collection and Use of Personal Information

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 may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you online or offline:

Category	Examples	Collected for a Business Purpose
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal Information described in California Civil Code § 1798.80(e)	A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment, employment history, bank account number, debit/credit card number or any other financial information, medical information, or health insurance information.	Yes
Protected Classification Characteristics	Age, race, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth, and related medical conditions), sexual orientation, veteran, or military status.	Yes
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Internet or other electronic network activity information	Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.	Yes
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information	Current or past job history or performance evaluations.	Yes
Non-public education information (Per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 CFR Part 99)	Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes
Sensitive Personal Information	A Social Security Number, driver’s license, state identification card, passport number, account log-in, financial account, debit/credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of a consumer’s mail, email unless the business is the intended recipient of the communication, biometric information processed for the purpose of uniquely identifying the consumer, personal information collected concerning a consumer’s health or sexual orientation.	Yes

 

Personal information does not include:

• Publicly available information that is lawfully made available to the general public from federal, state, or local government records.
• De-identified or aggregated consumer information.
• Information excluded from the CPRA’s scope:
  • 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 categories of sources:

• Directly from you or indirectly from you and/or your authorized representatives in connection with the services we provide.
• From third parties that interact with us in connection with the services we provide.
• From your web browser when you visit our website.
• From public sources.

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.
• To provide you with information, products, or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing.
• To serve and protect the rights, property or safety of us, our clients, our employees, or others, as necessary or appropriate.
• To respond to governmental authorities, including law enforcement requests, and as required by applicable law, court order, or governmental regulations.
• To process employment applications, make employment determinations, and manage and support our employees, including verifying eligibility and administering employment benefits.

We will not collect additional categories of personal information or use the personal information we collected for additional purposes for which the personal information was collected without providing you notice.

 

 

Disclosure of Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers
• Personal information described in Section 1798.80(e) of the California Civil Code
• Protected classification characteristics
• Commercial information
• Internet or other electronic network activity
• Professional or employment-related information
• Sensitive personal information

 

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

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

In the preceding twelve (12) months, we have not sold or shared any personal information. We do not have actual knowledge of selling or sharing personal information of minors under 16.

Retention of Personal Information

We retain personal information for as long as it is reasonably needed to perform the business purpose for which it was collected and consistent with applicable law. We strive to limit our retention of personal information for the least amount of time needed. The criteria we may use to determine the specific retention period of personal information include the type of information; the reason for collection; our reasonable business purposes for processing the information; and whether retention or deletion of the information is necessary to comply with legal obligations.

Security of Personal Information

Champlain has implemented reasonable security procedures and practices appropriate to safeguard, secure, and protect personal information from unauthorized or illegal access, destruction, use, modification, or disclosure in accordance with Civil Code section 1798.81.5. Nevertheless, security and privacy risks cannot be eliminated due to the nature of the Internet and Champlain cannot guarantee that information will not be disclosed in ways not otherwise described in this privacy policy.

If an unauthorized party breaches your personally identifiable information, we will comply with applicable state laws in notifying you of the breach.

Your Rights and Choices

The California Consumer Privacy Act of 2018, as amended, provides California consumers with specific rights regarding their personal information.. These rights are not absolute and may be subject to certain exceptions, exemptions, and verification.

 

 

Access to Specific Information and Data Portability Rights

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. You may also contact us to request access to personal information that you have provided to us. 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 purpose for collecting that personal information.
• The categories of third parties with whom we disclosed that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).

Correcting Inaccurate Personal Information Request Rights

You have the right to request that we correct any of your inaccurate personal information that we collected and retained, subject to certain exceptions. You may also contact us to request the correction of any inaccurate personal information that you have provided to us. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct the inaccurate personal information, unless an exception applies.

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 your personal information from our records, and will notify and direct all third parties, including service providers and contractors, to delete from their records any of your personal information that has been disclosed to them for a business purpose, unless an exception applies.

We may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with laws or for other purposes, solely to the extent permissible under this title.

Please note, however, we may deny your deletion request if retaining the information is necessary for us to:

1. Comply with legal process or federal, state, or local laws such as HIPAA, California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act, California Financial Information Privacy Act the Driver’s Privacy Protection Act, and the California Financial Information Privacy Act.
2. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
3. Ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
4. Exercise free speech to ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; and
5. Comply with a legal obligation.

Additional Rights

As a California resident, you have additional privacy rights under CPRA that are not applicable to Champlain due to our current information practices. These rights include:

• The right to opt-out of the sale or sharing your personal information; Champlain does not share or sell your personal information.
• The right to limit the use or disclosure of sensitive personal information; Champlain does not use or disclose sensitive personal information in that would require this right to be offered. The right to opt out of cross-context behavioral advertising; Champlain does not utilize cross-context behavioral advertising.

Exercising Access, Data Portability, Correction, and Deletion Rights

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

• Calling us toll free at 1-833-656-0017
• Emailing us at [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability 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.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  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 data portability 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.

Non-Discrimination

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

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of goods or services.
• Suggest that you may 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 to reflect changes to our personal information practices. The effective date at the top of the Privacy Policy is the date when it was most recently updated.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or you wish to exercise your rights under California law, please contact us at:

Toll-Free Phone: 1-833-656-0017

Website: www.cipvt.com
Email: [email protected]

 

Postal Address:

Champlain Investment Partners
Attn: Privacy Officer

180 Battery Street, Suite 400

Burlington, VT  05401