PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Updated and Effective: December 30, 2021
To the maximum extent permitted by the CCPA, and other than where provided in this Notice, this Notice does not apply to personal information reflecting a written or verbal communication or transaction described in Cal. Civil Code § 1798.145(n) (“B2B Personal Information”).
2. INFORMATION WE COLLECT
We collect 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.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope or from the CCPA’s definition of personal information, including, for example, 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, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A. Identifiers: YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): YES
C. Protected classification characteristics under California or federal law: YES
D. Commercial information: YES
E. Biometric information: NO
F. Internet or other similar network activity: YES
G. Geolocation data: NO
H. Sensory data: NO
I. Professional or employment-related information: NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): YES
K. Inferences drawn from other personal information: YES
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you, including without limitation when you:
- Inquire about our services and offerings
- Contact us through the Site
- Create an account at our Site
- Sign up for email updates
- Place an order
- Communicate directly with us about any of our products
- Enter a contest or sweepstakes
- Participate in a marketing survey, promotion, or event; or
- Provide us information when you otherwise conduct business with us.
- Indirectly from you, including without limitation by observing your actions on the Site.
- From an organization which you may have a relationship with, such as your employer.
- From our business partners.
3. USE OF PERSONAL INFORMATION
We may use, sell, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product on our Site, we will use that information to process your payment. We may use that information to inform you about other products you may be interested in. We may also save your information to facilitate new product orders.
- To provide, support, personalize, and develop the Site and our products and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your experience and to deliver content and product offerings relevant to your interests, including targeted offers and ads through the Site, third-party sites, and via email, text message, mobile app push notifications, and in app messages (with your consent, where required by law).
- To help maintain the safety, security, and integrity of the Site, products, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve the Site and our products.
- 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, including without limitation to respond to your verifiable requests for your personal information and its deletion.
- Other legitimate purposes in connection with our business, including without limitation evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
4. SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party or service provider for a business purpose.
We share your personal information with the following categories of third parties:
- Service providers
- Other third parties who we retain to perform services on our behalf to help with proposed or actual business activities, including without limitation, contractors, insurers, email and SMS vendors, hosting and development companies and payment processors, to help us market our products and services, process orders, perform market research, promotions management and otherwise assist us in running our business.
A. Disclosures of Personal Information for a Business Purpose.
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category J: Non-public education information
B. Sales of Personal Information.
In the preceding twelve (12) months, the Company has not sold your personal information.
5.YOUR RIGHTS AND CHOICES
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
A. Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
B. Deletion Request Rights.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
C. Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us emailing us at: [email protected]. Please include the title “Exercising Access, Data Portability, and Deletion Rights” in the subject line of your email request.
Only you, or someone legally authorized 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 or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we 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 us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
D. Response Timing and Format.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover 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. For data portability requests, we 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.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We do not currently provide any financial incentives.
This Section 6 also applies to B2B personal information.
7. OTHER CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law (Cal. Civil Code § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write us as set forth below.
8. CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of the Site following the posting of changes constitutes your acceptance of such changes.
9. CONTACT INFORMATION