CCPA Compliance
Emerging Markets Access & Capital International ("EMAC") is committed to respecting the privacy rights of California residents under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA). This page explains how we comply with these rights, even though we do not maintain a user registration system or store personal information in a database. isrameds.com
Scope and Applicability
The CCPA/CPRA applies to California residents and grants them specific rights regarding their personal information. While EMAC does not collect personal information through user accounts or forms, we may automatically collect certain data through website interactions, such as IP addresses, browser type, device identifiers, and usage patterns via analytics tools and cookies. This information may qualify as "personal information" under the CCPA/CPRA if it can be reasonably linked to a specific consumer or household.
Your Rights Under CCPA/CPRA
As a California resident, you have the following rights:
- Right to Know: You may request details about the categories and specific pieces of personal information we have collected about you in the past 12 months.
- Right to Delete: You may request deletion of your personal information we have collected, subject to certain exceptions.
- Right to Opt-Out of Sale or Sharing: You have the right to opt out of the "sale" or "sharing" of your personal information to third parties for targeted advertising. While we do not sell personal information for monetary consideration, we may allow third-party analytics and advertising partners to collect data via cookies for behavioral advertising, which may constitute "sharing" under CPRA.
- Right to Non-Discrimination: You may exercise your rights without being denied goods or services, charged different prices, or provided a different level of service.
- Right to Correct: You may request correction of inaccurate personal information we hold about you.
- Right to Limit Use of Sensitive Personal Information: You may limit our use and disclosure of sensitive personal information, such as precise geolocation data.
How We Comply
EMAC does not sell personal information for monetary consideration. We use third-party analytics services (e.g., Google Analytics) that may use cookies to collect browsing behavior for website optimization and advertising purposes. We do not retain personally identifiable data beyond what is necessary for analytics and security. We honor Do Not Sell or Share requests and provide a clear mechanism to exercise your rights.
Data We Process
Under CCPA/CPRA, the following categories of personal information may be collected automatically:
- Internet or other electronic network activity (e.g., pages visited, time spent, clickstream data)
- Device identifiers and IP addresses
- Geolocation data (approximate, via IP)
- Usage patterns and interactions with our content
No names, email addresses, phone numbers, or financial account details are collected or stored.
Legal Basis for Processing
Our processing of personal information is based on legitimate interests, including website functionality, security, analytics, and improving user experience. We do not rely on consent for this processing, but we respect your right to opt out of sharing for targeted advertising.
How to Exercise Your Rights
To exercise your CCPA/CPRA rights, please contact us at:
Email: [email protected]
Include your full name, California address, and a clear description of your request (e.g., "I want to opt out of the sale of my personal information" or "I request access to my personal information"). We may ask for verification of your identity to protect your privacy.
Response Timeframes
We will acknowledge your request within 10 business days and respond within 45 days. If additional time is needed, we will notify you and explain the reason for the delay. Responses are provided free of charge.
No Discrimination Policy
EMAC does not and will not discriminate against you for exercising your CCPA/CPRA rights. You will not be denied access to our content, charged different fees, or receive a lower quality of service because you exercised your privacy rights.
Updates and Changes
We may update this CCPA Compliance page periodically. Any material changes will be posted here with an updated "Last Updated" date. We encourage you to review this page regularly.
Contact Information
For questions, requests, or complaints regarding your CCPA/CPRA rights, please contact:
Michelle Caldwell
1317 Beacon St
Brookline, MA 02446
Email: [email protected]
For complaints about our compliance, you may also contact the California Attorney General’s Office.