Your California Privacy Rights Notice

This Notice describes the rights of consumers under the California Consumer Privacy Act of 2018 (“CCPA”). Hosky Communications, Inc. d/b/a FedInsider (“Hosky”) respects your privacy. This Your California Privacy Rights Notice (“California Privacy Notice”) applies solely to visitors, users, registrants, and others who are residents of the State of California (“consumers” or “you”).

Capitalized terms included in this California Privacy Notice that are not defined herein shall have the same definitions as set forth in Hosky’s Privacy Policy.

Hosky collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, including the following:
  • 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; and
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, Hosky may have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Hosky obtains the above categories of Personal Information from the following categories of sources:

• Directly from you if you provide your Personal Information to Hosky.
• Directly and indirectly from activity on Hosky’s Website or engagement with Content.
• Directly from Hosky’s prospects, customers, or their agents.
• Indirectly from Hosky’s prospects, customers, or their agents. For example, through information Hosky collects from Hosky’s customers in the course of providing services to them.

Hosky may use or disclose the Personal Information Hosky collects for one or more of the following purposes:

• To provide you with certified credits earned through interaction with Hosky’s forums.
• To fulfill or meet the reason you provided the Personal Information.
• To provide, support, personalize, and develop Hosky’s Website, the Content, and other Hosky IP.
• To create, maintain, customize, and secure your account with Hosky.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve Hosky’s responses.
• To help maintain the safety, security, and integrity of Hosky’s Website, the Content, Hosky’s IP, other Hosky technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Hosky’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Hosky is among the assets transferred.

Hosky will not collect additional categories of Personal Information or use the Personal Information that Hosky has collected for materially different, unrelated, or incompatible purposes without providing you notice.

Hosky may or disclose your Personal Information to a third party for a business purpose, including the disclosure of your Personal Information to its partners and/or its Content sponsors. When Hosky or discloses Personal Information as set forth above, Hosky enters a contract that describes the purpose and requires the recipient to keep that Personal Information confidential. Under the CCPA you have the right to opt out of Hosky selling your Personal Information to these third parties in accordance with Hosky’s Do Not Sell My Personal Information Notice.

Hosky discloses your Personal Information for a business purpose to the following categories of third parties:

• Hosky’s successors or assigns.
• Hosky’s contractors, business partners, Content sponsors, service providers, and other third parties Hosky uses to support Hosky’s business providers.
• A potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of
• Hosky’s assets (including in the event of a reorganization, dissolution or liquidation).
• Any competent law enforcement body, regulatory, government agency, court or other third party to: (i) comply with any court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply Hosky’s Terms and Conditions or terms of any other agreement; and (iii) protect the rights, property, or safety of Hosky or others.
• Any other person or organization with your consent to the disclosure and/or to fulfill the purpose for which you provide it.
• In the preceding twelve (12) months, Hosky may have disclosed the following categories of Personal Information for a business purpose:
  Identifiers.
  California Customer Records Personal Information categories.
  Protected classification characteristics under California or federal law.
  Internet or other similar network activity.
  Professional or employment-related information.

In the preceding 12 months, Hosky may have sold certain Personal Information as defined under the CCPA.

The CCPA provides consumers with specific rights regarding their Personal Information. This Section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information & Data Portability Rights:

You have the right to request that Hosky disclose certain information to you about Hosky’s collection and use of your Personal Information over the past 12 months. Once Hosky receives and confirm your verifiable consumer request, Hosky will disclose to you:

• The categories of Personal Information Hosky collected about you.
• The categories of sources for the Personal Information Hosky collected about you.
• Hosky’s business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom Hosky shared that Personal Information.
• The specific pieces of Personal Information Hosky collected about you (also called a data portability request).
• If Hosky disclosed your Personal Information for a business purpose,:
  • for disclosures for a business purpose, identify the Personal Information categories that each category of recipient obtained.

Deletion Request Rights:

You have the right to request that Hosky delete any of your Personal Information that Hosky collected from you and retained, subject to certain exceptions. Once Hosky receives and confirms your verifiable consumer request, Hosky will delete (and direct Hosky’s service providers to delete) your Personal Information from Hosky’s records, unless an exception applies.

Hosky may deny your deletion request if retaining the information is necessary for Hosky or Hosky’s service provider(s) to:

• Complete the transaction for which Hosky collected the Personal Information or otherwise perform Hosky’s contract with you; or
• Provide a good or service that you requested; or
• Take actions reasonably anticipated within the context of Hosky’s ongoing business relationship with you; or
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; or
• Debug Hosky IP to identify and repair errors that impair Hosky’s IP functionalities; or
• Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; or
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); or
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; or
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
• Comply with a legal obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability & Deletion Rights:

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Hosky at:

Hosky Communications, Inc. d/b/a FedInsider
Attn: Peg Hosky, President
3811 Massachusetts Avenue, NW
Washington, DC 20016

Email: privacy@hosky.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows Hosky to reasonably verify you are the person about whom Hosky collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows Hosky to properly understand, evaluate, and respond to it.

Hosky cannot respond to your request or provide you with Personal Information if Hosky cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with Hosky. Hosky will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing & Format:

Hosky will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt of such request. If Hosky requires more time, Hosky will inform the requestor of the reason and extension period in writing, which may be extended for up to an additional forty-five (45) days (90 days in total from the date of receipt of the verified consumer request).

Hosky will deliver a written response via email, if your request is either made via email or an email address is provided in a verified consumer request that is mailed; provided however, Hosky will provide a written response via regular postal mail to the address you provided in the consumer verified request if a response by mail is expressly requested in the consumer verified request.

Any disclosures Hosky provides will only cover the 12-month period preceding the verifiable consumer request’s date of receipt. The response Hosky provides will also explain the reasons Hosky cannot comply with a request, if that is the case. For data portability requests, Hosky will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Hosky does not charge a fee to process or respond to your verifiable consumer request, unless it is excessive, repetitive, or manifestly unfounded and unreasonable. If Hosky determines that a fee is warranted for your request, Hosky will inform you the reasons under which Hosky has warranted such fee and provide you with an estimated cost of such fee prior to completing your request.

Non-Discrimination:

Hosky will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Hosky will not:

• Deny you goods or services; or
• Provide you a different level or quality of goods or services.

Any CCPA-permitted Program that Hosky offers will reasonably relate to your Personal Information’s value and contain written terms describing the material details of such Program. Your prior “opt in” consent, which you may revoke at any time, is required to participate in any such Program.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Hosky’s Website users, that are California residents, to request certain information pertaining to Hosky’s disclosure of Personal Information to third parties for their direct marketing purposes. Please contact Hosky at privacy@hosky.com, to make such a request.

Hosky reserves the right, in its sole discretion, to update, change, modify, add, or remove portions of this California Privacy Notice from time to time and without notice. No amendment, modification, extension, limitation, waiver, or termination of this California Privacy Notice by you shall be valid except with the written consent of Hosky. Hosky encourages you to periodically review this page for the latest information regarding Hosky’s California Privacy Notice. Your continued use of the Website and other Hosky IP is subject to the most current effective version of Hosky’s California Privacy Notice. If you object to this California Privacy Notice after it becomes effective for you, you may no longer use or access the Hosky IP, including the Website.

If you have any questions or comments about this notice, the ways in which Hosky collects and uses your Personal Information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact Hosky at:

Hosky Communications, Inc. d/b/a FedInsider
Attn: Peg Hosky, President
3811 Massachusetts Avenue, NW
Washington, DC 20016

Email: privacy@hosky.com

NEW: California’s “Do Not Sell My Personal Information” right and what it means for California residents who use Hosky.

The California Consumer Privacy Act of 2018 (“CCPA”) aims to provide California residents a host of new rights, including the ability to prevent companies from “selling” their Personal Information.

A common understanding of “selling” information is that it involves a company taking information it has learned about you and exchanging that information with an unrelated third party for money, who will then use that data for a new purpose that you did not intend. However, the CCPA has a much broader definition of “sell” than this, which is described in more detail below.

Hosky strives to comply with the CCPA, and your wishes, as it relates to this right. Hosky details how Hosky does this in the sections below.

What does Hosky do that may fall under the CCPA’s definition of “sell”

• We disclose, disseminate, make available, and/or transfer Personal Information to our third-party partners and Content sponsors as part of a partnership or sponsorship contract.
• We disclose Personal Information and other data to service providers, affiliates, and other third-parties as described in Hosky’s Privacy Policy

This list is not meant to be exclusive but shows examples of how Hosky may use your Personal Information.

Why does Hosky do this?

• Sharing Personal Information with Hosky’s partners and Content sponsors allows Hosky and these third parties to design, develop, and provide additional content, materials, training, and other resources that may be of interest to you and the larger government communities.
• Sharing Personal Information with service providers, affiliates, and other third parties allows Hosky to provide you with improved access to Hosky IP, including Content, and to provide improved security features for Hosky’s users.

All of the above is crucial to Hosky providing the best user experience possible for its users and is important to Hosky’s core purposes. For example, when you register for Content, Hosky may provide your Personal Information to the Content’s sponsor, which helps both Hosky and the Content sponsor understand who is registering for specific Content for purposes of developing future Content that would be informative for those individuals. A request to not “sell” (that is, “transfer”) your information runs counter to this activity and prevents Hosky and the Content sponsor from improving its Content offerings.

Hosky does not sell data to data brokers.

How can I opt-out?

The transfers Hosky notes above are inherent in Hosky’s services. To opt out of these transfers, you can request that Hosky delete your account and Personal Information by emailing Hosky at privacy@hosky.com.

By submitting this request, you are declaring that you are a California resident availing yourself of the rights afforded to you under the CCPA.

Once your data is deleted, then Hosky is unable to transfer it.

Please Note that opting out does not prevent you from accessing the Website or registering for Content. You may still access the Website and Content after asserting your right to opt-out.