PRIVACY POLICY SUPPLEMENT FOR CALIFORNIA RESIDENTS

Last Modified: May 12, 2020

This Privacy Policy Supplement (this “Supplement”) applies to California residents and supplements the information contained in Harvard Business Services, Inc.’s broader privacy policy (the “Privacy Policy”), available here. The Supplement applies to all California residents who visit www.delawareinc.com (the “Website”), the website of Harvard Business Services, Inc. (the “Company”, “we”, “us”). Such persons are referred to herein as "consumers" or "you". We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Capitalized terms used but not defined herein have the meaning set forth in the Privacy Policy and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

For a description of the information we collect and how we collect that information, please see our Privacy Policy.

Use of Personal Information

We will not sell your personal information or other information to any third-party for any purpose.

For a description of how we use the personal information we collect, please see our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes than described in the Privacy Policy without providing you notice and, if applicable, seeking your consent or giving you the right to opt-out of such use.

Sharing Personal Information

The limited circumstances under which we disclose or share personal information are set forth in the Privacy Policy.

When we disclose personal information to a third party for a business purpose (e.g., to provide you with services or products that you purchase where such disclosure is necessary), we enter a contract that describes the purpose of the disclosure and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the past twelve (12) months from the date hereof, the Company has not shared personal information of its Website users, formation or registered agent clients, or others, for a business purpose.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights under the CCPA 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 twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you for the past twelve (12) months:

• The categories of personal information we have collected about you,

• The categories of sources for the personal information we collected about you,

• Our business or commercial purpose for collecting 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), and

• If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient (as set forth in the CCPA) 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 provider(s) to:

• 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation, including a non-destruction of records order issued with a subpoena or otherwise, a recordkeeping obligation imposed by law or regulation, or other law or regulation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

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

• Calling us at 1 (800) 345-2677 or 1 (302) 645-7400
• Emailing us at privacy@delawareinc.com

Only you, or someone legally authorized 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 (should such child violate the restriction on the Website to those over 18).

You may only make a verifiable consumer request for access or data portability twice within a twelve (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, which may include, in our discretion:

• The username and password on your client account (MyControlDesk), including answers to security questions answered at the inception of your account (or later modified),

• A government-issued ID, such as a passport, U.S. drivers’ license, or other government-issued ID;

• Social security number, taxpayer ID number, or another government-issued identifier, or

• Such other material or information as we deem appropriate under the circumstances

You must 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.

Opt-out of Sales of Financial Information

The Company does not sell consumers’ information to third parties.  Therefore, the opt-out rights for this practice do not apply.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (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 twelve (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.  The Company will determine such format as appropriate under the circumstances.

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 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.

We do not provide any financial incentive to consumers for the use of personal information as permitted under the CCPA.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time, as described in the Privacy Policy.

Contact Information

If you have any questions or comments about this notice, the ways in which Harvard Business Services, Inc. collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-345-2377

Website: www.delawareinc.com

Email: privacy@delawareinc.com

Postal Address:

16192 Coastal Highway

Lewes, Delaware 19958