CALIFORNIA PRIVACY PROTOCOL (CCPA/CPRA)

Effective Date: April 11, 2026

Overview: The California Mandate

This California Privacy Notice ("Notice") serves as a specialized supplement to the Kaufman & Kaufman, LLC. ("The Firm") Privacy Protocol. It applies exclusively to "Consumers" as defined by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). In the event of a conflict between general Firm policies and this Notice, this protocol shall prevail for California residents. The Kaufman & Kaufman Standard: * Data Integrity: The Firm does not sell personal data for monetary gain or commercial brokerage.

Operational Focus: We treat data as a technical necessity for managing high-fidelity assets and principal relations.

Data Acquisition & Forensic Categories

The Firm collects and maintains specific categories of Personal Information (P.I.) strictly for the administration of the Kaufman & Kaufman archive and the protection of principal assets.

Category of P.I.Sources of Acquisition Operational Purpose

Identifiers (Name, IP, Email, SSN)Direct Principal Input / Automated Systems Security, Fraud Prevention, Asset Verification

Personal Records (Financials, Signatures), Fiduciary Correspondence, Transactional Integrity, Trust Management

Commercial Information (Purchase History)Transaction Logs Archive Provenance, Portfolio Tracking

Internet Usage (Browsing Metadata)Archive Tracking Tools System Optimization, Security Auditing

Geolocation Data, Mobile Application Interface, Tactical Utility, Security Protocols

Professional/Employment InfoDirect Fiduciary InputFiduciary Verification, Trust Integration

The "Do Not Sell" Mandate

Kaufman & Kaufman, LLC. does not sell your Personal Information. The Firm restricts the use of P.I. to the specific business purposes associated with your asset management and the security of the Archive. While California law requires an "Opt-Out" mechanism for the "sale" of data, our standing policy is a total prohibition on the commercial sale of principal records.

Principal Rights (California)

California residents are entitled to the following rights regarding their data within the Kaufman Archive:

The Right to Know: You may request disclosure of the specific categories and pieces of P.I. The Firm has collected information about you over the preceding 12-month period (limit: twice per year).
The Right to Delete: You may request the deletion of P.I. collected directly from you, subject to legal retention requirements (e.g., maintaining records for IRS compliance or trust litigation).
The Right to Correct: You may request that the Firm rectify any inaccurate P.I. within our archives.
The Right to Non-Discrimination: The Firm will not alter service levels or access to assets based on your exercise of privacy rights.

The Verification Protocol

To protect the integrity of the Archive, every request is subject to a Forensic Verification Process. The Firm will only fulfill requests for which we can reasonably verify the Consumer's identity. This may involve:

Direct Confirmation: Cross-referencing provided data with existing Archive records.
Authorized Agents: If utilizing an agent, we require written, notarized permission or a Power of Attorney issued under the California Probate Code.

Contact & Compliance

To exercise your rights under California law, or for further technical inquiry, contact the Firm's Compliance Officer:

Kaufman & Kaufman, LLC.

Attn: Allen Kaufman, Managing Director, Data Privacy and Technology Compliance

Reference: California Privacy Inquiry

P.O. Box 24594

Chattanooga, TN 37422-4594

Institutional Line: +1 (800) 798-9636

Electronic Correspondence: r.kaufman@kaufmanandkaufman.com