Your privacy is important to us at The Churchill Companies (“Churchill,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act, and implementing regulations.
This California Privacy Policy (“Policy”) describes how we collect, use, share, disclose, retain, and secure the personal information we gather about you through our website, https://www.churchillcompanies.com/ (collectively, the “Site”), or when you interact with us otherwise (collectively, the “Services”), that is subject to the CCPA. It does not apply to personal information that is excluded or exempted.
We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.
What Information Do We Collect?
The below examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.
In the previous 12 months, we have collected the following categories of personal information:
| Category | Examples | Collected | Retention Period |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes | Duration of the relationship or as required by law |
| B. Personal Information | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories. |
Yes | Duration of the relationship or as required by law |
| C. Protected Classification Characteristics Under California or Federal Law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes | Duration of the relationship or as required by law |
| D. Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | No | N/A |
| E. Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No | N/A |
| F. Internet or Other Similar Network Activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes | 26 months |
| G. Geolocation Data | Physical location or movements. | No | N/A |
| H. Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information. | No | N/A |
| I. Professional or Employment-Related Information | Current or past job history or performance evaluations. | Yes | Duration of the relationship or as required by law |
| J. Non-Public Education Information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes | Duration of the relationship or as required by law |
| K. Inferences Drawn of the Consumer | Inferences drawn from personal information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes | 26 months |
| L. Sensitive Personal Information | Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or (f) genetic data.
Biometric information processed for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Some Sensitive Personal Information included in this category may overlap with other categories. |
Yes | Duration of the relationship or as required by law |
Sources From Which Personal Information Is Collected
We collect your personal information directly from you, from your interaction with the Site, from publicly available sources, and from service providers and third parties which collect the personal information directly from you.
Business or Commercial Purposes for Which Personal Information Is Collected
Your personal information is used for the following purposes: to provide the Services and Site; advertising and marketing; analytics and research; diligence and investing, employment, website security and maintenance; and for legal, regulatory, and other compliance purposes. Please see our Privacy Policy for additional information.
Third Parties with Whom Personal Information Is Disclosed, Shared, or Sold
In the preceding 12 months, we have disclosed the following personal information about consumers for business purposes:
- We disclose personal information in all categories with service providers.
- We may disclose personal information in categories A (identifiers), B (personal), C (protected), I (employment), J (education), and L (sensitive) with third party benefits providers that provide benefits to employees.
- We disclose content posted on our social media platforms with other consumers. Such posts may include personal information in categories A (identifiers) and B (personal), but the content depends on the individual posts. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.
- We may share information in all categories with affiliates, investors, or portfolio companies in connection with providing the Services or otherwise in connection with business operations.
In the preceding 12 months, we have not shared information for the purposes of cross context behavioral advertising.
In the preceding twelve (12) months, we have not sold the personal information of any consumer for monetary consideration. However, our use of cookies may be considered a sale of personal information under the CCPA. Categories of personal information that we have sold under the CCPA include categories F (internet) and K (inferences). Categories of third parties to whom personal information is sold under the CCPA include data analytics providers.
You can opt out of the sale or sharing of your personal information through our Your Privacy Choices page by clicking on the circular icon in the lower left corner of the webpage. You may also opt out by enabling the Global Privacy Control (GPC) through certain browsers. Please note that your use of our website will still be tracked by Churchill and its service providers.
We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.
Individual Rights
- Right to Know About Personal Information Collected, Disclosed, Shared, or Sold
You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties. There are two types of Rights to Know requests that you can make:
- Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
- Categories of personal information collected, sold, or shared;
- Categories of sources from which personal information is collected;
- Categories of third parties to whom the information is sold, shared or disclosed;
- Business or commercial purpose for collecting, sharing, or selling personal information;
- Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
- Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
- Specific pieces of personal information collected about you.
This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.
- Right of Deletion
You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.
- Right to Opt-Out of the Sale or Sharing of Personal Information
You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations. You can opt out of the sale or sharing of your personal information through our Your Privacy Choices page by clicking on the circular icon in the lower left corner of the webpage. You may also opt out by enabling the Global Privacy Control (GPC) through certain browsers.
Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.
- Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
- Right of Correction
If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request. Taking into account the nature of the personal information and purposes of processing the personal information, you have the right to request that we correct inaccurate personal information about you, if applicable.
- Right to Limit Use and Disclosure of Sensitive Personal Information
If we process Sensitive Personal Information, we will only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.
- Submitting Requests
You can submit your request by visiting our Data Subject Request page, emailing us at info@churchillcompanies.com or by calling us at (612) 673-6700.
- Verifying Requests
To ensure the protection of your personal information, we must verify that the individual submitting a request to know, request to delete, or request to correct is the consumer to whom the request relates prior to processing the request. To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.
- Authorized Agents
You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in Underdog denying your request.
Contact Us
If you have any questions about this Privacy Policy, please contact us by email at info@churchillcompanies.com or at 333 South Seventh Street, Suite 3100, Minneapolis, MN 55402.
