1. Introduction 

This California Privacy Policy is for California residents and supplements our privacy policy available on our website. This policy explains how we collect, use, and share your Personal Information and how to exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”) as amended, modified, or replaced from time to time. For purposes of this policy, the term “Personal Information” includes all “Personal Information” as defined in the CCPA. This policy consists of four parts: 

• The CCPA Categories of Personal Information We collect, use, store, and disclose 
• We Do Not Sell Your Personal Information 
• Your CCPA Rights 
• How you can enforce your rights  

Please also note that the definition of “Personal Information” under CCPA is subject to certain exceptions as set forth therein and does not include information that is publicly available or has been aggregated or de-identified in accordance with CCPA or is covered by other relevant legislations such as Health Insurance Portability and Accountability Act (HIPAA), Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and the Drivers Privacy Protection Act (DPPA).  

This policy was released on 30^th June 2022. 

This California Privacy Policy was last updated on 1^st July 2024.   

2. Personal Information we collect, use and disclose 

In the past 12 months, we have or may have collected the following information about you. Please note that the following list represents categories of Personal Information across all California residents whose Personal Information we may have collected or received. However, it does not necessarily represent the information that we have collected specifically about you: 

We may have collected and processed Personal Information for various business purposes in the preceding 12 months, which includes: 

• Audits related to interactions with consumers in connection with the professional services that LTTS provides. 
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking appropriate action as a result of any such detected activity. 
• Debugging to identify and repair errors that impair existing intended functionality. Short-term, transient uses where the Personal Information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the relevant interaction.  
• Performing professional services for our clients. 
• Undertaking internal research for technological development and demonstration. 
• Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services. 
• We may disclose your Personal Information to a third party for a business purpose. In the preceding 12 months, we may have disclosed the categories of Personal Information mentioned in the table above. 

We disclose your Personal Information for a business purpose to the following categories of third parties: 

• Our affiliates. 
• Service providers. 
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you. 

3. We do not Sell your Personal Information 

As per CCPA, ‘Sale of Personal Information’ means selling, renting, releasing, disclosing, dissemination, making available, transferring, or otherwise communication orally, in writing, or by electronic or other means, a consumer’s Personal Information by the business to another business or a third party for monetary or other valuable consideration. We do not sell your Personal Information for monetary consideration. However, we may allow certain third parties (such as online advertising services) to collect your browsing activity and certain other Personal Information via automated technologies for a business purpose which does not amount to ‘Sale of your Personal Information’ under the CCPA. We may share the categories of Personal Information listed below in order to improve the performance of our website, to enhance your browsing experience, to provide you a more personalized browsing experience, and to improve our advertising efforts. You can view a full listing of those third-party cookies and opt-out of their use through the ‘Disabling Cookies’ section in our cookie policy.  

In the preceding 12 months, we may have disclosed the following categories of Personal Information in connection with such third-party cookies: 

• Identifiers. This includes www.ltts.com visitors’ internet protocol (“IP”) addresses. 
• Internet or network activity. This includes information about visitors’ interaction with ltts.com, including information about the visitor’s web browser, page location, referrer, and person using the website; cookie-specific data such as cookie ID and the cookie; and button and field data, such as any buttons clicked by site visitors, the labels of those buttons, any pages visited as a result of the button clicks, and the names of any website fields filled in by visitors. 

However, you may choose to opt-out any time of disclosure of your Personal Information to third parties by emailing us at dpo@ltts.com. 

4. What rights do I have? 

You have the following rights under certain circumstances: 

• Right of access and data portability 

You may have the right to request that we disclose to you information about our collection and use of your Personal Information in the preceding 12 months, including (a)  the categories and specific pieces of Personal Information we collect; (b) the categories of sources from which we collect or sell Personal Information; (c) the business or commercial purpose for which we collect Personal Information; (d) the categories of third parties with whom we share Personal Information; and (e) the categories of Personal Information disclosed for a business purpose or sold to third parties and the categories of third parties to whom such Personal Information was sold or disclosed.  

• Right to deletion 

You may request that we delete certain Personal Information that we have collected about you.  The foregoing is subject to our right to maintain your Personal Information for specific purposes permitted under CCPA.  If we are unable to comply with any such request, we will notify you.  

• Right to opt-out 

You may have the right to opt-out of the ‘Sale of your Personal Information’ to third parties. 

• Right to non-discrimination 

Should you exercise any of your privacy rights as a California Consumer, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.  However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information. 

As part of processing your request, we require you to provide specific Personal Information about you in order to verify your identity in accordance with the CCPA requirements. This information includes your first and last name, email address, physical address, telephone number, and description of relationship to LTTS, but may also include additional information based on the nature of your request and your relationship with us. 

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about certain Personal Information we shared, if any, with other businesses for their own direct marketing use in the previous calendar year. Hence, if you are a California resident, you may have the right to request that we disclose your information about our collection and use of your Personal Information in the preceding 12 months, including: 

• the categories of sources from which we collect or sell Personal Information. 
• the business or commercial purpose for which we collect Personal Information. 
• the categories of third parties with whom we share Personal Information; and 
• the categories of Personal Information disclosed for a business purpose or sold to third parties and the categories of third parties to whom such Personal Information was sold or disclosed. 

Additionally, in accordance with your rights under the CCPA, you may designate an authorized agent to make a request on your behalf. In order to comply with your request, we will require the Personal Information referenced above to be used for identity verification purposes, as well as the name, email address, and telephone number of your authorized agent. 

Please note that you may only make an access request to us for your Personal Information up to two times in any 12-month period. 

To request a copy, please write to us at dpo@ltts.com. 

5. Exercising my rights / registering complaints or grievance 

You may use any of the following methods to exercise your rights or register any grievance / complaint related to our processing of your Personal Information or linked to our processing in accordance with applicable data protection principles, our policies, and procedures: 

• Write an email to our Data Protection Officer at dpo@ltts.com. 
• Fill the form CCPA California Consumer Request Form | L&T Technology Services (ltts.com)for submitting your requests. 
• Exercise your right to opt-out of ‘Sale’ by filling the form on CCPA California Consumer Request Form | L&T Technology Services (ltts.com)on our website 
• You may directly opt-out of third-party cookies through ‘Disabling Cookies’ section in our https://www.ltts.com/cookie-policy. 

It should be noted that there may be situations where providing the information requested by you would disclose Personal Information about another individual. In such cases, information may be redacted or withheld as may be necessary or appropriate to protect that person’s rights.  

If you have any questions regarding this Policy, you can contact LTTS’s Data Privacy Office at dpo@ltts.com or by submitting the request form CCPA California Consumer Request Form | L&T Technology Services (ltts.com).