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Extract to table / employee-privacy-training-materials.pptx
employee-privacy-training-materials.pptx
Parties
Program Cascade Retail Holdings Inc
Harkness LLP
Cascade Retail Holdings Inc
Cascade Digital Marketplace LLC
Ridgeline Fulfillment Services Inc
Peakview Analytics Inc
Cascade Rewards Corp
Fieldhaven Consulting Group LLC
Dates
November 13, 2025
December 15, 2025
June 2, 2025
August 15, 2025
September 12, 2025
September 30, 2025
October 31, 2025
December 1, 2025
December 31, 2025
January 1, 2026
Amounts
$480
$18.4
Obligations
and subject to financial-incentive disclosure rules All data access must comply with the documented data-retention and disposal schedule No documented data-retention schedule existed prior to this program — one is now in place [slide 9] Module 4: Data Subject Requests (DSRs) — Overview Consumer rights include: Right to Know/Access, Right to Delete, Right to Correct, Right to Opt-Out of Sale/Sharing, Right to Limit Use of Sensitive PI Additional state-specific rights: Right to Appeal (required by Virginia, Colorado, Connecticut, and other states) FY2024 volume: ~38,400 total DSRs received (Access: ~12,800; Deletion: ~19,100; Opt-Out: ~6,500) Prior average response time: 27 calendar days — new target: 15 business days or less Universal opt-out mechanism (Global Privacy Control) must now be honored — this was a prior gap [slide 10] Module 4 (cont
72 hours to regulators under some statutes) All incidents are logged and investigated under the internal privacy policy procedures [slide 12] Module 6: Vendor & Third-Party Management Cascade shares consumer data with 47 third-party advertising and analytics partners 23 of these 47 partners previously lacked executed Data Processing Agreements (DPAs) — a critical gap now being remediated Under CCPA/CPRA, each vendor must be classified as a Service Provider, Contractor, or Third Party All vendors must have an executed DPA before receiving any personal information Key vendors: OnPoint Data Solutions (CMP, $480K/yr); Thornbridge Media Corp