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Our Contact Details
If you have any questions about our privacy practices, how we use your personal information, your choices, and rights, or would like to exercise your rights under California law, please contact us.
citrin cooperman
Attn: Privacy Office
50 Rockefeller Plaza
New York, New York 10020, USA
Toll free telephone:
888-450-2221
Email:
privacy@citrincooperman.com
Introduction
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
This Privacy Notice describes how Citrin Cooperman and its subsidiary entities collect, use, share, sell, disclose, retain, dispose of, and protect Personal Information when you interact with us as a subscriber, client, prospective client, office visitor, website user, job applicant, employee, contractor, supplier, event attendee, or any other relevant individual, and describes the choices you have relating to your Personal Information and how to exercise such rights.
Applicability
This Privacy Notice supplements the Citrin Cooperman Privacy Notice and addresses state-specific disclosures required under the This California Consumer Privacy Act, (“CCPA”). This California Consumer Privacy Act, (“CCPA”) Notice (“California Notice”) describes how we handle your Personal Information, the reasons we do so, and the rights you have as a California resident regarding your information. This Privacy Notice supplements the Citrin Cooperman Privacy Notice and uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations.
This Privacy Notice applies to any Personal Information you provide to Citrin Cooperman and any Personal Information we collect during your employment, when you apply to a job posting, contact us, visit, or use our website, “www.citrincooperman.com” and all websites linked to this website, when you visit a Citrin Cooperman office, attend a Citrin Cooperman event or seminar, or request a service from us. The Personal Information we collect varies depending on the nature of the services we provide and how you interact with us. To use this site, you do not need to send us any Personal Information.
In this Privacy Notice, "Personal Information," is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. Personal information does not include (i) publicly available information from government records, (ii) deidentified or aggregated consumer information, or (iii) information excluded from the CCPA's scope, such as (a) 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, or (b) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), or the Driver's Privacy Protection Act of 1994.
This Privacy Notice applies to any Personal Information you provide to Citrin Cooperman and any Personal Information we collect when you contact us, visit, or use our website, “www.citrincooperman.com" and all websites linked to this website, visit a Citrin Cooperman office, attend a Citrin Cooperman event or seminar, or request a service from us. The Personal Information we collect varies depending on the nature of the services we provide and how you interact with us.
At Citrin Cooperman, we value your privacy and are committed to safeguarding your information as part of our ongoing dedication to providing a secure and transparent experience for our users. As a result, we are committed to keeping our Privacy Notice up to date, reflecting any changes in our Personal Information practices or the adoption of new privacy policies. Should you have any questions or concerns about our Privacy Notice or how we process your Personal Information, please do not hesitate to reach out to us.
Your Personal Information
At Citrin Cooperman, we offer a wide range of Assurance, Tax, and Advisory services to meet the business and personal needs of our clients. Given the diversity of our Service offerings, we process broad categories of Personal Information, including Sensitive Personal Information. We use your Personal Information for lawful business purposes, including (i) using only Sensitive Personal Information provided by you with your consent, (ii) performance of a contract, and/or (iii) complying with legal and regulatory obligations.
We also collect and use your Personal Information when you apply for a job to assess your suitability for job opportunities and provide you with personalized experiences. Additionally, we collect and use your Personal Information as an employee to manage the employment relationship, communicate with you, improve the workplace and our services, protect the health and safety of our employees, and comply with legal and regulatory requirements.
We process your Personal Information for the following purposes:
- To provide products and services to you
- To comply with legal/regulatory requirements
- To operate and improve our business
- To manage our workforce and provide them with employment, training, compensation, or benefits
- For marketing and advertising purposes
- To improve the security and performance of our website, network, systems and services
- To protect against fraud and abuse
- To protect the safety and security of our employees and clients
- To communicate with you about our products and services
- To operate and understand your use of our website
You may have executed a contract, such as a Master Services Agreement (MSA), Statement of Work (SoW), Engagement Letter or other Agreement, that governs the relationship between you and Citrin Cooperman and the services we provide to you. If there is any conflict between the terms of your agreement with Citrin Cooperman and the terms of this Privacy Notice, the terms of your agreement will prevail.
Type of Personal Information We Collect
We may have collected the following categories of Personal Information within the last twelve (12) months, including Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
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Browsing and Device Information
Like many companies, your visit to our website triggers automatic collection of cookies and other tracking technologies. We and third parties, including our third-party service providers may automatically collect certain details about your device and browsing, like IP address, browser type, and page views through the use of cookies and other tracking tools like analytics and pixels. This information may be used to understand your interests and needs, improve the performance of our marketing campaigns, improve the performance of our website, personalize the content and advertising that we show to you, prevent fraud and abuse, comply with legal requirements, or improve the security of our website, systems, and services. If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using this link.
Please visit our Cookies and Other Tracking Technologies Notice for more information.
Children’s Data
Our services are not directed at Children, and we do not knowingly collect any Personal Information from Children under the age of 16 without prior verifiable parental consent.
Certain Citrin Cooperman services, may process Personal Information related to Children, such as their date of birth, address, or other identifiable information to fulfill our service obligations to you. This Personal Information is not collected directly from Children, but from other parties such as your representative, or directly from you as the parent or guardian of the Child (e.g., so that the Child may be named a beneficiary to an insurance policy or pension plan).
If Citrin Cooperman learns that a Child under the age of 16 has submitted Personal Information without parental consent, we will take all reasonable measures to delete the data as soon as possible and to not use such data for any purpose, except where necessary to protect the safety of the Child or others as required or allowed by law. If you believe a Child under the age of 16 has provided us with Personal Information, please contact us at privacy@citrincooperman.com or use the mailing address below.
Categories of Third Parties with Whom Personal Information Is Potentially Disclosed
During the 12-month period prior to the last updated date of this California Notice, we may have disclosed your Personal Information with certain categories of third parties as disclosed below. We may need to disclose your Personal Information in certain circumstances as outlined below to carry out our business. We take your privacy seriously and will only disclose your Personal Information when it is necessary to do so. Furthermore, we have put in place safeguards to protect your Personal Information and will only disclose it to third parties who have agreed to protect it as well.
- Third-party suppliers, service providers, affiliates, and business partners: Citrin Cooperman may disclose Personal Information to third-party suppliers, service providers, affiliates, and business partners to assist us in meeting business operation needs and to deliver our services and functions.
- Vendors: Citrin Cooperman may disclose Personal Information to vendors who provide services to the firm, such as information technology services, cloud computing services, and data storage services. This is done to allow these vendors to perform their services effectively and efficiently.
- Investors: Citrin Cooperman may disclose Personal Information to investors to provide them with information about the firm's financial performance and operations. This disclosure is necessary for investors to make informed investment decisions.
- Regulators: Citrin Cooperman may disclose Personal Information to regulators to comply with legal and regulatory requirements. For example, Citrin Cooperman may be required to disclose Personal Information to the Securities and Exchange Commission in connection with an audit of a public company.
- Law enforcement: Citrin Cooperman may disclose Personal Information to law enforcement agencies if required to do so by law. For example, Citrin Cooperman may be required to disclose Personal Information to the Federal Bureau of Investigation in connection with an investigation of a financial crime.
Sale and Share, Including Cross-Contextual Behavioral Advertising
California’s expansive definition of "sale" means that even non-monetary exchanges, such as any instance where a consumer's personal information is transferred or disclosed to a third party, in exchange for any form of valuable consideration, constitutes a "sale," regardless of whether monetary compensation is involved.
We may sell or share Personal Information with third parties for various purposes, including cross-context behavioral advertising. We use third-parties, such as Google Analytics, Sitecore, and Demandbase, to automatically collect Browsing, Contact, Device, Personal Detail and Social Media Information using Cookies and Other Tracking Technologies, such as web beacons and/or pixels on our behalf when you are using our site and other platforms. These services allow us to improve the performance of our website and to personalize the content and advertising that we show to you. In the process of setting cookies and tracking technologies, to provide Citrin Cooperman with certain analytics services on our site, some third-party providers, may retain such analytics data for their proprietary purposes, including cross context behavioral advertising. Since the retention of analytics data may impact the price of the analytics services to Citrin Cooperman, it may be deemed a Sale of Personal Information.
- Google Analytics
We use the services of Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and other similar technologies to help analyze how visitors use the sites. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Google Analytics, please refer to https://www.google.com/policies/privacy/partners. Google offers the ability to opt-out of tracking through Google Analytics cookies. For more information, please visit https://tools.google.com/dlpage/gaoptout. Google has developed the Google Analytics Opt-out Browser Add-on to provide website visitors with more choices on how their data is collected by Google Analytics. The add-on communicates with Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics opt-out browser add-on does not prevent information from being sent to the website itself or to other web analytics services. You can also opt out of Google Analytics by declining cookies for advertising.
- Sitecore
We use the services of Sitecore, a digital experience platform (DXP) that helps us create and manage digital content and experiences. Sitecore uses cookies and other similar technologies to help analyze how visitors use the sites to create and deliver personalized digital experiences to you. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Sitecore, please refer to Sitecore Privacy Policy | Sitecore. Sitecore offers the ability to opt out of tracking through Sitecore cookies. For more information, please visit Your privacy choices (sitecore.com). Sitecore has a Privacy rights request form which you may use to facilitate Opt-out requests and provide you with more choices on how your data is collected by Sitecore. You can also opt out of Sitecore collection and processing by declining cookies for Analytics and Targeted Advertising (“Do Not Sell” Opt Out).
- Demandbase
We use the services of Demandbase, a go-to-market (GTM) platform that helps us identify and engage prospective clients. Demandbase and their analytics/service providers use tracking pixels, tags, web beacons and cookies to collect information. These technologies are used in analyzing trends, tracking users’ online movements, and gathering demographic information about our user base. Our site offers the ability to turn off tracking cookies. For more information about the collection and use of data through Demandbase, please refer to Demandbase Privacy Notice. Demandbase offers the ability to opt out of tracking through their Privacy Preference Center. Demandbase has a Privacy rights request form which you may use to facilitate Opt-out requests and provide you with more choices on how your data is collected by Demandbase. You can also opt out of collection and processing by declining cookies other than those that are strictly necessary.
- Vena Solutions
In the course of providing our services, we may share your personal details and contact information with Vena Solutions, as we are an authorized reseller of their solutions. This sharing is essential for ensuring that you receive optimal support and access to the features of the Vena platform. We are committed to safeguarding your information and will only share what is necessary to fulfill your requests and enhance your experience with our services. For more details on how Vena Solutions handles your data, we encourage you to review their privacy policy.
- Cookies and Other Tracking Technologies
Please see our Cookies and Other Tracking Technologies Notice to better understand our use of Cookies and Other Tracking Technologies, including your rights and how you can control your Personal Information collected from Cookies and Other Tracking Technologies. Turning off cookies also does not end collection of data through pixels. Pixels, also known as web beacons or clear GIFs, are small, transparent images that can be embedded in websites and emails. Turning off cookies will prevent websites from setting cookies on your browser. However, it will not prevent pixels from setting cookies on your browser, as pixels are not cookies, but are simply images. If you are concerned about your privacy, you can control which pixels are accepted by your browser by adjusting your privacy settings. Most browsers allow you to block all pixels or to only accept pixels from certain websites. To further understand your Individual Rights, see the section, “Exercising Your Data Protection Rights,” below.
- Social Media
We may use third-party marketing Cookies and Other Tracking Technologies to help deliver advertisements relevant to your interests. These include:
- Facebook: You can learn more about Facebook cookies and how you can control them at Meta Cookies Policy | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy.
- Google/YouTube: You can learn more about Google cookies and how you can control them at How Google uses cookies – Privacy & Terms – Google
- LinkedIn: You can learn more about LinkedIn cookies and how you can control them at Cookie Policy | LinkedIn
- Hubspot: You can learn more about Hubspot cookies and how you can control them at HubSpot Cookie Policy.
Third-Party Links and Services
This site and all websites linked to the website contain third-party links that can be used to access certain services provided by third parties. This Privacy Notice does not address data collection or processing by any of those parties.
Do Not Track/Global Privacy Control (GPC)
Do Not Track (“DNT”) or “Global Privacy Control” is a preference setting offered by various internet browsers, whereby a signal is automatically sent by the browser to each website visited requesting that the user’s activities are not tracked by that website and that the website does not enable onward tracking to other websites. You can usually access your browser’s DNT option in your browser’s preferences. If that occurs, the website visited will not recognize you upon return to that website or save your passwords or usernames, and some other features of a website may become unavailable or not function properly.
Retention
How long we retain your Personal Information depends on the purpose for which it was obtained and its nature. This includes providing you with a service you have requested from us or to comply with applicable legal requirements, including complying with the law, retaining records, resolving disputes, and enforcing our agreements. This storage period may extend beyond the term of your relationship with us. We will keep your Personal Information for the period necessary to fulfil the purposes described in this Notice unless a longer retention period is permitted or required by law and in accordance with the Citrin Cooperman Record Retention Policy.
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Data Subject |
Retention |
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Client Representative |
Personal information will be retained in the Citrin Cooperman’s CRM for as long as we have, or need to keep a record of, a relationship with a business contact. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Clients |
We retain the personal information processed by us in accordance with the terms of our client agreements. We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Contractors |
Personal information will be retained about our contacts at our contractors, for as long as it is necessary for the purposes set out above (e.g., for as long as we have, or need to keep a record of, a relationship with a contact, which is for the duration of our relationship with a contact or their organization). Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Corporate (Prospective Corporate Acquisition) |
We retain the personal information processed by us in accordance with the terms of our Corporate agreements. |
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Employees |
We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Event Attendees |
We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Job Applicants |
We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Office Visitors |
We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Prospective Clients |
Personal information will be retained in the Citrin Cooperman’s CRM for as long as we have, or need to keep a record of, a relationship with a business contact. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Subscribers |
Personal information will be retained in the Citrin Cooperman’s CRM for as long as we have, or need to keep a record of, a relationship with a business contact. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Third Parties |
Personal information will be retained about our contacts at our suppliers for as long as it is necessary for the purposes set out adjacent (e.g., for as long as we have, or need to keep a record of, a relationship with a contact, which is for the duration of our relationship with a contact or their organization). Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights. |
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Website Users |
We will retain the personal information collected by us through the Site for as long as is necessary for the purpose(s) for which it was collected as set out above, provided that personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards, and in order to establish, exercise or defend our legal rights. |
Your Data Protection Rights
As a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA) to control your personal information.
- Right to Delete Personal Information. Subject to certain exceptions, such as our ability to comply with a legal obligation, you have the right to request that we delete the Personal Information we have collected from you upon verifiable request. California residents may make Requests to Know up to twice every 12 months.
- Right to Correct Inaccurate Personal Information. Subject to certain exceptions, you can ask us to fix any inaccurate Personal Information we have about you upon verifiable request. California residents may make Requests to Know up to twice every 12 months.
- Right to Know What Personal Information Is Being Collected/Right to Access Personal Information. You can ask us what Personal Information we collect about you and how we use it upon verifiable request. California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily usable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:
- categories of Personal Information collected.
- categories of sources of Personal Information.
- business and/or commercial purposes for collecting and selling their Personal Information.
- categories of third parties/with whom we have disclosed or shared their Personal Information.
- specific pieces of Personal Information.
- Right to Know What Personal Information Is Sold or Shared and to Whom. You can ask us what Personal Information we sell or share and to whom we sell or share it with upon verifiable request. California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily usable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their Personal Information in the prior 12 months, including:
- that we have disclosed or shared with a third party for a business purpose;
- categories of Personal Information collected; and
- categories of third parties to whom the residents’ Personal Information has been sold and the specific categories of Personal Information sold to each category of a third party.
- Right to Opt Out of Sale or Sharing of Personal Information. You have the right to tell us not to sell or share your Personal Information at any time (the “right to opt out" of sale/share, including Cross-Context Behavioral Advertising). The CCPA defines a "sale" as disclosing or making personal information available to a third party in exchange for money or other item of value. You can opt out of sale or share, including for Cross-Context Behavioral Advertising by going to the Data Subject Request Form; Opt-out of Sale/Sharing of My Personal Information (including for Targeted Advertising). We do not knowingly sell Personal Information about California residents who we know are under 16 years of age without their opt-in consent. You also have the right to opt out of information Citrin Cooperman shares from cross-context behavioral advertising purposes. To exercise the right to opt out of “sale” or “share,” you may also indicate your cookie preferences by visiting our Cookie and Other Automated Technologies Notice.
- Right to Limit Use and Disclosure of Sensitive Personal Information. We only collect, process, and share Sensitive Personal Information when necessary to meet contractual obligations, fulfill our services to you, or comply with regulatory obligations. If you believe we have collected, processed, or used your Sensitive Personal Information for any other other purpose, please contact us and we will limit its use or sharing. You can ask us to limit how we use and disclose certain Sensitive Personal Information by going to the Data Subject Request Form.
- Right to Object to Direct Marketing. You have the right to object to the processing of your Personal Information for direct marketing at any time. We will provide specific information on how to opt out of our marketing initiatives within the method of communication, such as by email. If you wish to modify your preferences in respect to updates or notifications, or the mailing lists to which you subscribe, you can modify your preferences using this link. All commercial and marketing communications (e.g., notification emails and newsletters) include instructions for opting out of those communications.
Automated Decision Making
While we don't rely solely on automated systems to make decisions about you, we may use profiling techniques like analyzing background checks to assist in tasks like assessing client eligibility. This helps us ensure responsible service provision and protect both you and us.
Exercising Your Data Protection Rights
Only you, or someone you have legally authorized to act on your behalf, can make a verifiable consumer request related to your Personal Information. You can also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of someone else, we may ask for additional information to protect their Personal Information, such as proof that you are authorized to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestors’ identity or authority to make the request.
We cannot respond to your request, except for requests to Opt-out of Sale/Sharing of My Personal Information or provide you with your Personal Data if we cannot verify your identity or authority to make the request, or if we cannot confirm that the Personal Data relates to you or your minor child. We may also be unable to comply with your request if we have a legal or regulatory obligation to keep your Personal Data, such as when the Personal Data is necessary to complete a transaction. Other reasons your request may be denied are if it jeopardizes the privacy of others or would be extremely impractical to honor.
Your request must:
- Provide enough information so that we can reasonably verify that you are the person whose Personal Information we collected or received from an authorized representative.
- Describe your request in enough detail so that we can understand, evaluate, and respond to it.
To the extent any of the above rights are applicable and you would like to exercise your rights, please leverage our Data Subject Access Request Form, by email at privacy@citrincooperman.com, or by phone at (888) 450-2221. You are not required to pay any charge for exercising your rights.
Anti-discrimination
We cannot and will not discriminate against you for exercising your CCPA rights. Specifically, we will not:
- Deny you services.
- Charge you different fees or rates for services, including using discounts or other benefits, or imposing penalties.
- Provide you with a different level or quality of services.
- Suggest that you receive different rates for services or services of a different level or quality.
Enforcement and Dispute Resolution
If you have a dispute with us regarding your CCPA rights, please leverage our Data Subject Access Request Form and select option “Appeal Citrin Cooperman's Refusal to Take Action on a Request.” We will attempt to resolve the dispute with you directly. For more information about how California residents may file a complaint with the California Privacy Protection Agency (“CPPA”) pursuant to the CCPA, see the California Privacy Protection Agency (CPPA) website.
Shine the Light
California residents also have the right to request that we provide you with (a) a list of certain categories of Personal Information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address above.
Changes to This Notice
We may update this Statement occasionally. When we do, we will post the current version on this site, and we will revise the version date located at the top of this page. We encourage you to periodically review this Notice so that you will be aware of our privacy practices.
View the full Citrin Cooperman Privacy Notice
Accessible Format
This Privacy Notice is available to individuals with disabilities. To access this Privacy Notice in an alternative downloaded format, please click here.