Champlain Investment Partners, LLC takes your privacy seriously. This Policy outlines information you may wish to know about how we collect and use your information via our website.
We collect information from website visitors as they navigate the public portions of our website. We do not use this information to market directly to or solicit business from website visitors.
We reserve the right to change this policy at any time should we deem it advisable to do so. Please revisit this address to view updated or modified policy.
EFFECTIVE DATE: JANUARY 1, 2020
PRIVACY NOTICE FOR CALIFORNIA EMPLOYEES AND CLIENTS OF CHAMPLAIN INVESTMENT PARTNERS, LLC
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Notice of Champlain Investment Partners, LLC (collectively, “we,” “us,” or “our”). This supplemental privacy notice gives California residents the additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”).
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 may have collected the following categories of personal information from employees and clients of the firm, both herein referred to as “consumers,” within the last twelve (12) months:
|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.|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|Professional or employment-related information.||Current or past job history or performance evaluations.|
|Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’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. For example, from documents that our clients provide to us related to the services for which they engage us.
- From third-parties that interact with us in connection with the services we perform. For example, from our fund administrator for funds we advise on.
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 open a new account, we will share that information with our fund administrator;
- 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 into between you and us, including for billing;
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others; and
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
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 you notice.
Sharing 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 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:
- California Customer Records personal information categories
- Protected classification characteristics under California or federal law
- Commercial information
- Internet or another similar network activity
- Professional or employment-related information
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
- 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 any personal information.
Your Rights and Choices
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 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. 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 (also called a data portability request).
- 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.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- 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;
- 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;
- 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
- Comply with a legal obligation.
Exercising Access, Data Portability, 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:
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.
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 through granting discounts or other benefits, or imposing penalties.
- Provide you 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. When we make changes to this privacy notice, we will notify you by email or through a notice on our website.
If you have any questions or comments about this notice, our Privacy Statement, 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 at:
Postal Address: Champlain Investment Partners
Attn: Privacy Officer
180 Battery Street, Suite 400
Burlington, VT 05401