Privacy Notice

The Cypress Praxis, LLC Privacy Policy (“Policy”) describes the policies and procedures we use to collect, use, disclose, share, and protect your Personal Information. Throughout this Policy, we refer to information that personally identifies you or your accounts (such as your name, email or mailing address, phone number, account credentials – user id and passwords- social security number, government ID numbers and other information that can be used to identify you personally) as “Personal Information”.

We collect personal information in the normal course of business in order to manage your account(s) and to serve you. We do this through our application process, in the course of performing our business as well as through interviews and ongoing dialogues with you in person, via phone, or email or Zoom.
We do not sell your personal information to anyone.
We take steps to protect the confidentiality and security of your personal information.
We restrict access to personal information to any employees or agents, who are trained to safeguard such information, for business purposes only.
We maintain physical, electronic, and procedural safeguards to guard your personal information.
We do not disclose personal information to third parties, unless one of the following limited exceptions applies:
We may disclose personal information to companies that help us process or service your transactions or account(s).
We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, to comply with a Court Order or to resolve any possible disputes.
We use your personal information to fulfill our regulatory obligations and to help us deliver and offer the best possible service to you.
We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date.
If you identify any inaccuracy in your personal information, or you need to make a change to that information, please contact us so that we may promptly update your records.
We will provide you notice of significant changes to our Privacy Policy.

If you have any questions or concerns regarding this policy, please contact us:

By phone at 415-499-3300 or via email at [email protected].

This update was adopted as of July 31, 2024.

California Consumers: You can find supplemental information regarding your rights under the California Consumer Privacy Act (CCPA) in the next section.

Privacy Notice for California Residents

This Privacy Notice for California residents (“Notice”) supplements The Cypress Praxis’s Privacy Notice and applies to all individuals who reside in California (“consumers,” “you,” or “your”). The Cypress Praxis, LLC has adopted this Notice (collectively, “Cypress” “we,” “our,” or “us”) whose activities fall within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

For the purpose of this Notice, personal information does not include information that is exempted from the CCPA, such as personal information covered by other privacy laws such as the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, or the California Financial Information Privacy Act. Depending on whether you have or had a business relationship with us, the CCPA may not apply to you or all of your personal information.

Personal Information We Collect

We have collected the following categories of personal information (collected and used solely within the context of California residents’ roles, as listed here) from consumers (including consumers who are job applicants to or employees, or contractors of Cypress) within the last 12 months. We have also listed the categories of information we do not collect about you, unlike some other vendors of services:

Identifiers such as real name, postal address, email address, telephone number, online identifiers, Internet Protocol address, driver’s license number, Social Security number, passport number, government issued identification, or other similar identifiers;
Protected classification characteristics under California or federal law such as age and gender;
Financial and commercial information such as investment background and experience, that you have provided us and
Inferences drawn from such information.
We do not purchase information from other sources about you.
We do not seek Internet or other network activity information such as information regarding your interaction with our websites, applications, and advertisements, biometric information (such as voice authentication and call recording), and geolocation data.
We do not seek professional or employment related information, which includes information necessary to conduct background screenings, unless you are a job applicant or contractor with us.

How We Use Your Information

We have used or disclosed the personal information collected for one or more of the following business purposes within the last 12 months (excluding uses or disclosures we may be prohibited from reporting under applicable law):

To conduct our business, including providing our products and services, and, where necessary, in order to assist us in verifying your identity, and to provide support, personalize, and develop our products and services;
To fulfill and respond to your inquiries and requests, including providing you with support, investigating and addressing your concerns, monitoring, and improving our responses, and to otherwise carry out the purposes for which you provided the information;
To personalize your experience with our business and to deliver content, product, and service offerings relevant to your interests;
To perform in connection with your roles, responsibilities, and/or status as a job applicant to or an employee, or contractor of Cypress, including administering payroll, benefits, maintaining compliance with policies and procedures, and to comply with health and safety and occupational health obligations;
To help maintain the safety, security, and integrity of our business, including all products and services, and to respond, where necessary, to requests from regulators and law enforcement or as otherwise required by applicable law, regulation, court order, or similar demand;
As described to you when collecting your personal information or as otherwise set forth in the CCPA; and
To evaluate or conduct a merger, reorganization, dissolution, or other sale or transfer of some or all of Cypress’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cypress is among the assets or business operations transferred.

Personal Information Disclosed for Business Purposes

We have disclosed the categories of personal information listed above for business purposes to the following categories of parties within the last 12 months (excluding disclosures we may be prohibited from reporting under applicable law):

Third parties to whom you direct or authorize us to disclose your personal information, independent of or in connection with products and services we provide to you.

Cypress has not and does not intend to sell your personal information to third parties or others.

Your CCPA Data Rights

The CCPA provides consumers with certain data rights with respect to the personal information businesses collect. You may exercise any of the listed data rights (subject to certain exceptions and limitations), by following the “Instructions for Submitting a Verifiable CCPA Data-Rights Request” provided below.

You have “Rights to Know”:

The specific pieces of personal information we have collected about you;
The categories of personal information we have collected about you;
The categories of sources from which your personal information is collected;
The categories of personal information that we have disclosed for a business purpose about you;
The categories of third parties to whom personal information was disclosed for a business purpose; and
The business purpose for collecting personal information.

You also have the right to “Request to Delete” your personal information: You may request that we delete personal information about you that we have collected from you (unless an exception applies, or deletion is otherwise restricted or prohibited by law, rule, or regulation).

Instructions for Submitting a Verifiable CCPA Data-Rights Request

Please following these instructions carefully.

You may submit a verifiable request to us by either calling or emailing us.

What to expect once you submit a request. We will work to confirm receipt of your request within 10 days (and provide you with information on how we will process your request, including our verification process) and to respond to your request within 45 days from the date of our receipt of your request (unless additional time is necessary, and, in such cases, we will explain to you the reason it may take more than 45 days to respond).

We may ask you to provide additional information in order to verify your identity. We will only use any additional information we collect for the purposes of verifying your identity and for security or fraud-prevention purposes. In cases where additional information is required and we are unable to contact you with the contact information you have provided, we may be unable to respond to your request.

Current Cypress Clients: If you are a current Cypress client (or an agent with your own account-access credentials acting on behalf of a current Cypress client), you may submit your requests.

Former or Non-Cypress Clients: If you are a former Cypress client or not a Cypress client (or an agent acting on behalf of a former or non-Cypress client), please submit your requests email.

Your name, phone number, and either your email and mailing address (we may use this information you provide to assist us in verifying your identity and to communicate with you if necessary); and
State the specific data rights requests you are making. For example, you can state “I want to know the categories of personal information you have collected about me.” Please refer to the list of available data rights above.

Please do not provide any additional information. We will contact you directly or provide you with additional instructions.

Authorized Agents

A consumer can designate an authorized agent to make a data-rights request under the CCPA on the consumer’s behalf.

Agents acting on behalf of current Cypress clients: Please follow the instructions above for agents acting on behalf of current Cypress clients.
Agents acting on behalf of a former or non-Cypress client: Please follow the instructions above for agents acting on behalf of a former or non-Cypress client.
Who is an “authorized agent”? An authorized agent is a person, or a business entity registered with the California Secretary of State that a consumer has authorized to act on their behalf. If you are an authorized agent and submit a data-rights request on behalf of a consumer, we may require that the consumer provide you with written authorization to make the request on their behalf and verify their own identity directly with us.

Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of these data rights. Cypress does not discriminate against any consumer for exercising their rights under the CCPA

CCPA Data Rights Are Not Available for Certain Personal Information

CCPA data rights are not available for personal information we collect about you in the course of you acting as a job applicant to or an employee, owner, director, officer, or contractor of Cypress, including, in these contexts, your emergency contact information and personal information that is necessary for us to retain to administer benefits for another person relating to you acting as a job applicant to or an employee, owner, director, officer, or contractor of Cypress. Any personal information we collect, and use will only be used within the context of your role or former role in these capacities.

We recognize data privacy is an ongoing responsibility. We reserve the right to update or amend this Notice from time to time and any such updates or amendments will be reflected in the Notice available on our website.

We adopt this Notice to comply with CCPA Section 1798.130(a)(5).

Last Updated: January 15, 2021