The CA Addendum describes our policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit, or we obtain when you access our website, as well as when you:
- Use our mobile Site or applications,
- Visit one of our stores or attend one of our events,
- Call or email us,
- Interact with us on social media, or
- View our online advertisements.
1. Information We Collect:
We may collect or have collected in the preceding 12 months the following categories of personal information (“PI”).
- Identifiers. Examples include the real name, postal address, online identifier, Internet Protocol internet protocol address, and email address or other similar identifiers.
- Other elements. Examples include name, signature, characteristics or description, address, telephone number, bank account number, credit card number, other financial information.
- Geolocation data. This might include location information while using our apps.
2. Purposes for Which We Collect Your Information:Set forth below are the business or commercial purposes for which we have collected your PI.
- To provide you with information, products or services that you request from us.
- To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To engage in marketing activities, including to help design products and services appropriate for our clients.
- To communicate with you in social media concerning our products and services.
- To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
- To review, improve, and monitor our Site, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
- To provide customer service and engage in quality control activities concerning our products and services.
3. Sources of Personal InformationThe categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.
You. Examples of when we collect that information include:
- During a Site visit, or when you visit us at one of stores or events.
- If you upload or share information, submit a request, submit information, or post other digital content through one of our Site, applications or via social media interactions on third-party websites like Facebook or Twitter.
- In connection with your interactions with us as a registered user of our Site or online services.
4. Sharing Information
Of the categories of PI noted above, during the past 12 months, we shared the following:
- Third parties as directed by you.
- Third parties who perform services on our behalf.
- Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.
5. Selling Personal Information
We do not sell your PI and have not sold any PI in the preceding 12 months, including any information concerning minors under age 16. Except as otherwise noted, we do not track your activities online over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.
6. Consumer Rights
Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.
7. Request to Delete
You have the right to request that we delete your PI from our records and direct any service providers to delete your PI from their records, subject to certain exceptions.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your PI from our records.
We are not required to comply with your request to delete your PI if it is necessary for us (or our service provider) to maintain your PI in order to:
- Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you.
- Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
8. Request to Know
You have the right to request that we disclose the following to you as it relates to the 12-month period preceding our receipt of your verifiable consumer request:
- The categories of PI We have collected about you.
- The business or commercial purpose for collecting PI.
- The categories of sources from which the PI is collected.
- The categories of PI we disclose about you for a business purpose
- The categories of third parties with whom we share PI.
- The specific pieces of PI We have about you.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to your request for information.
We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.
10. Submitting Consumer Rights Requests
To submit any of the Consumer Rights requests as outlined above, please contact us at email@example.com. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is: i. the consumer who is the subject of the request, ii. a consumer on behalf of the consumer’s minor child, or iii. by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive personal information to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used for any other purpose. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension. 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 receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period. You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with Us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.