CCPA

CCPA Online Privacy Notice

This California Consumer Privacy Act (“CCPA”) privacy notice (this “CCPA Notice”) is included in our Online Privacy Policy and applies to Wilshire Advisors, LLC’s ("Wilshire") processing of ‘personal information,’ as defined in the CCPA, of California residents who visit our website (collectively, “ Consumers,” “you,” or “ your”). Any capitalized terms or other terms not defined herein shall have the meaning ascribed to them in the Online Privacy Policy or, if not defined herein or in the Online Privacy Policy, the CCPA. To the extent of any conflict between this CCPA Notice and the rest of our Online Privacy Policy, this CCPA Notice shall control only with respect to Consumers and their personal information. If you are located elsewhere, please see our Online Privacy Policy HERE.

You may find a copy of this CCPA Notice in PDF format HERE . For individuals with disabilities, alternative methods of viewing or receiving this CCPA Notice can be found HERE.

General

This CCPA Notice provides further detail regarding (a) how we have processed Consumers’ personal information within the past twelve (12) months and (b) your rights under the CCPA.

Personal Information We May Collect

We collect and disclose the following personal information for our business purposes, including:

• To perform the contract we have entered into with you (contract) – this includes, but is not limited to, where we have entered into an agreement with you and the Personal Data is needed to ensure that the terms of the contract can be fulfilled;
• To comply with a legal obligation (legal obligation) – these obligations include, for example, where we have a regulatory obligation to conduct customer due diligence or are required to provide information to tax authorities; or
• Our legitimate business purposes (business purposes) – this includes the provision of services by us and our direct marketing activities. To this end, we will use your Personal Data to deliver services to you and/or to work or act for you. Furthermore, we will also use your Personal Data to inform you about us and our services and to build our relationship with you.

Your CCPA Rights

Access

You may request that Wilshire disclose certain information regarding our use of your personal information over the past twelve (12) months. You may only make such requests twice per twelve (12) months.

Upon verifying your request (see below), we will disclose to you:

• 1. The categories of personal information we collected about you.
• 2. The categories of sources for the personal information we collected about you.
• 3. The specific pieces of personal information we collected about you.
• 4. Our business purpose for collecting that personal information.
• 5. The categories of third parties with whom we share personal information.

Deletion

You have the right to request that Wilshire delete any of the personal information collected from you and retained by us, subject to certain exceptions. Once your request is verified (see below) and we have determined that we are required to delete that information in accordance with applicable law, we will delete and direct our service providers to delete your personal information from our records. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Exercising Your Rights

To exercise any of the rights described above, please submit a request to us by either:

Please note that Consumers have a right to not receive discriminatory treatment for the exercise of their rights under the CCPA.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. Your verifiable consumer request must:

• Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf; and
• Describe your request with sufficient detail to properly understand and respond to it.

We will only use the personal information that you have provided in a verifiable consumer request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Making a verifiable consumer request does not require you to create an account with us. We consider a request made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account.

Verifying Your Request

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. In all cases, your request must be verified before we take action (and shall take such action pursuant to the timing permitted under the CCPA). Verifying your request may require you to:

• Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf; and
• Describe your request with sufficient detail to properly understand and respond to it.

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Making a verifiable request does not require you to create an account with us. We consider a request made through your password-protected account sufficiently “verified” when the request relates to personal information associated with that specific account and you have complied with any of our existing authentication practices.

Response Timing and Format

We aim to respond to customer requests within forty-five (45) days of receipt. If we are unable to deliver a response to verifiable consumer requests within this timeframe, we will inform you of the reason and estimated extension period in writing. We will deliver a response to your existing account with us, if applicable, or a written response by mail or electronically, at your option.

Any disclosures will cover only the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Data portability requests will be issued in a format that is readily useable, we do not charge a fee unless your request is excessive, repetitive, or manifestly unfounded. If the request warrants a reasonable fee, we will tell you why and provide you with a cost estimate before completing your request.

Fees

Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Changes to this Privacy Notice

If, in the future, we intend to process your personal information for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately (either within this CCPA Notice or elsewhere), and the “Effective Date” at the top of this page will be updated accordingly.

Further information

If you have any queries, questions, concerns or require any further information in relation to this CCPA Notice or you wish to exercise any of your rights, please do not hesitate to contact Wilshire at: Privacy@wilshire.com.

The response period may be extended up to forty-five (45) additional days where necessary, taking into account the complexity of your request.