Privacy Notice for California Consumers
Your Right to Know About the Personal Information We Collect About You
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”), and we collected from the following sources:
· Directly from you as a customer. For example, when you (or your agent) call us to place an order, customer information and order information is obtained.
· Directly and indirectly from activity on our websites. For example, when submissions are made through our website portal or website, the content of the submission and usage details are collected automatically.
· When a customer places an inbound phone order, customer information and order information is obtained.
· Facebook, Google, Bing, Yahoo, and similar website that have the ability to direct potential customers to our website via search inquiries, cookies, and other tracking technologies.
In particular, we collected the following categories of personal information from consumers within the last twelve (12) months as follows:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Inferences drawn from other personal information.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
· To fulfill or meet the reason for which the information is provided.
· To provide you with information, products or services that you request from us.
· To 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 carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
· To improve our website and present its contents to you.
· For testing, research, analysis and product development.
· To estimate our audience size and usage pattern.
· To learn what information is of most and least interest.
· To speed up your searches.
· As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
· To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To evaluate or conduct 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.
Sharing Personal Information
We may disclose your personal information to a third party or a service provider for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have 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 under California or federal law.
We disclose your personal information for a business purpose to the following categories of third parties:
· Direct Mail remarketers;
· List rental companies;
· Service providers; and
· Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have sold the following categories of personal information:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law
Category D: Commercial information.
Your Rights and Choices
Under California Laws, California residents can exercise three privacy rights (Disclosure and Access; Deletion; and “Do Not Sell My Personal Information”), which are described in more detail below (collectively, “Rights”). These Rights are not absolute and are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us or the security of the business’s systems of networks. If you are a California consumer, we will process your request to exercise your Rights in accordance with California Laws.
A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.
Disclosure and Access Requests
You have the right to request that we disclose to you, for the 12-month period immediately preceding the date of your request to know the following:
Categories of Personal Information Request
· 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.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
º sales, identifying the personal information categories that each category of recipient purchased; and
º disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Specific Pieces of Information Request
· The specific pieces of personal information we collected about you (also called a data portability request).
When a request for disclosure is made, we will first take steps to verify your identity to protect your privacy and security. For requests to disclose categories of personal information collected, we will have the requestor provide at least two pieces of information so that we may verify the requestor’s identity to a reasonable degree of certainty. For requests to disclose specific pieces of personal information collected, we will have the requestor provider at least three pieces of information so that we may verify the requestor’s identity to a reasonably high degree of certainty and additionally provide a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. We are required to retain the signed declarations as part of our record-keeping obligations for 24 months.
Please note that we will never disclose a consumer’s social security number, driver’s license number, or other government-issued identification number, financial account number, any health information or medical identification number, an account password, or security questions and answers in response to a disclosure request.
Please note additionally that we are only required to fulfil a Disclosure request from a consumer twice per every 12-month period. If you submit a request in excess, it may be denied or you may be charged for fulfilling your request.
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. Given the type of personal information we collect, for requests to delete personal information collected, we will have the requestor provide at least three pieces of information so that we may verify the requestor’s identity to a reasonably high degree of certainty. We are required to retain the requests to delete for a period of 12 months as part of our record-keeping obligations.
If we are unable to verify a request, to the extent possible, that request will be treated as a request to opt-out and afforded rights associated with that request right as described in more detail below.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. A deletion request may be denied, in full or in part, if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Disclosure and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
· Email us at firstname.lastname@example.org
Only you 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.
Do Not Sell My Personal Information Requests
You have the right to direct us not to sell your personal information to a third party.
Further, you may designate an authorized agent to make a Do Not Sell My Personal Information request, but that agent will have to provide proof of the authorized agent’s written permission to do so. We will also require the authorized agent verify their identity corresponding to the written permission. (The verification requirement does not apply if the consumer has provided the authorized agent with legal power of attorney under California Probate Code Sections 400 to 4465.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 disclosure 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.
Requests to Opt-In for Minors
If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time. We do not and will not sell personal information of consumers we actually know are less than 16 years of age unless we received affirmative authorization from the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, to opt-in to the sale of their personal information. Upon the receipt of this request to opt-in, we will inform the minor of the right to opt-out later and of the process for doing so.
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.
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 notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address: B2C Response, LLC., 8601 NW 27th St. Doral, FL 33122 Attn: CS-CCPA