Certain states maintain consumer privacy laws (CPLs) designed to give consumers privacy rights over the personal information that CPS collects. These consumer privacy laws require CPS to provide consumers a Notice, at or before the point of collecting personal information, which describes the categories of personal information collected, the business purposes for which CPS collects or uses the personal information, if the personal information will be sold or shared, and the intended retention period.
CPS collects personal information in connection with its marketing, application, and other internet websites, including but not limited to CPS.com, and through oral and written communications with CPS personnel. As discussed below, CPS discloses personal information to service providers and contractors for business purposes.
Categories of Consumer PI Collected.
CPS may collect the following categories of consumer PI:
Business Purposes for Collecting Consumer PI.
CPS uses consumer PI to:
Categories of Service Providers/ Contractors to Whom CPS Discloses Consumer PI.
CPS discloses consumer PI to the following categories of service providers / contractors:
CPS will not use the personal information it collects for materially different, unrelated, or incompatible purposes than those listed above without first providing you notice.
A. Sources of Personal Information from Whom CPS Collects: CPS obtains the categories of personal information listed above from the following sources:
1. Directly from consumers through CPS’ websites when consumers voluntarily provide their personal information to CPS. Consumers may provide their personal information to CPS when they express interest in obtaining information about CPS or CPS products and services, participate in activities on the websites, purchase products or services, or complete a form requesting contact from CPS. The personal information CPS collects depends on the context of the consumers’ interaction with CPS and the websites, the choices they make, and the products and features they use.
2. Directly from consumers through verbal and written communications with CPS representatives, including job applications, reference materials, forms (including employment, payroll, and benefits administration), messaging applications, email, and the “Comments” section of the websites.
3. Indirectly from consumers by collecting information about their actions on CPS websites when consumers visit, use, or navigate the websites. This information does not reveal their specific identity but may include device and usage information, such as their IP address, browser, and device characteristics, operating system, language preference, referring URLs, device name, country, location, information about how and when they use CPS’ websites, and other technical information.
4. Indirectly from consumers by collecting information about their use of CPS resources. CPS automatically collects certain information when consumers log into and out of CPS information systems and when they access CPS properties and systems that are monitored with security system surveillance in the form of physical security, badge readers, and network security.
5. Public databases. CPS collects certain information about consumers through lawful use of public databases, including the OIG Exclusions Database and state licensure boards.
6. Service providers and contractors. CPS collects certain information about consumers from CPS’ services providers and contractors, including those that complete background surveys for CPS employment and contracting purposes, regularly monitor the OIG Exclusions Database, and coordinates recruitment and application processing.
7. CPS affiliates. CPS may receive personal information about consumers from ITS affiliates. CPS affiliates are also subject to this policy.
Selling or Sharing Your Personal Information. CPS does not sell or share for cross-context behavioral advertising consumer personal information with third parties.
Processing Your Personal Information. CPS does not process consumer personal information for targeted advertising or profiling.
Retention of the Personal Information CPS Collects. CPS will retain personal information for as long as needed or permitted, considering the purpose(s) for which it was collected. The criteria used to determine CPS’ retention periods include:
1. The length of time CPS has an ongoing relationship with the consumer.
2. Whether CPS has a legal obligation to maintain or destroy personal information.
3. Whether retention is advisable considering CPS’ legal position, such as enforcing the website’s Terms and Conditions, applicable statutes of limitation, litigation, or regulatory investigations.
Contact CPS. For questions or concerns regarding how consumers’ personal information is used or to exercise your consumer rights, please contact CPS by:
1. Submitting an email to CPS.Privacy@CPS.com
2. Calling CPS at 1-833-450-4229.
3. Submitting a written verifiable request by mail to CPS Solutions, LLC 655 Metro Place South Suite 450 Dublin, Ohio 43017-3520 ATTN: CPS Compliance Officer, Corporate Compliance Department.
Exercising Consumer Rights. A consumer or their authorized representative can exercise their rights by submitting a verifiable request to CPS. CPS is required to provide consumers with information only after the request is verified, and the requestor is determined to be the consumer about whom CPS has collected information. A verifiable request must:
1. Provide sufficient information that allows CPS to reasonably verify the consumer is the person about whom CPS collected personal information, which should include identifiers such as name, postal address, telephone number, email address, and locations and dates of service.
2. Describe their request in sufficient detail that allows CPS to properly understand, evaluate, and respond appropriately.
3. Once CPS receives the request, we will verify the demographic information we received as part of the request matches the consumer information we have on file. If applicable, we will determine if the authorized representative has the authority, either by operation of law or from the consumer, to receive the requested information. If the requestor is the person duly authorized on behalf of a consumer, please explain how or why the requestor is authorized to make the request on behalf of the consumer and include supporting documentation or the consumer’s consent.
Appealing an Adverse Consumer Rights Decision. If CPS declines the consumer’s request to exercise their rights, the consumer can appeal CPS’ decision by submitting a Written Statement of Disagreement. This written statement will be reviewed by someone who was not directly involved in the initial denial. Within 60 days of receipt of the appeal, CPS will inform the consumer, in writing, of action taken regarding the appeal, including a written explanation of the reason for the decision. Consumers can also file a complaint with the applicable state’s Attorney General.
Last updated: October 5, 2023
California Consumer Privacy Act (CCPA)
California Privacy Rights Act (CPRA Prop 24)
Virginia Consumer Data Protection Act (VCDPA) SB 1392
Nevada SB 220 / NRS 603A
Colorado Privacy Act SB 190
Connecticut Data Privacy Act SB 6
Utah Consumer Privacy Act SB 227
Montana Consumer Data Privacy Act (MCDPA)SB 384
Tennessee Information Protection Act (TIPA) HB 1181