California Consumer Privacy Act
CALIFORNIA INFORMATION If you are a California resident, you have certain rights with respect to your personal information. Those rights and how you may exercise them are described below. The fact that you have elected to exercise these rights will have no adverse effect on the price and quality of our products.
RIGHT TO REQUEST INFORMATION ABOUT DISCLOSURE TO THIRD PARTIES FOR THEIR DIRECT MARKETING PURPOSES. You may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes. To make such request, please email us at email@example.com. Please allow up to 30 days for us to process your request. You may submit such a request once per year.
RIGHT TO KNOW. You may request that we provide you for the last 12 months a list of the categories of personal information we have collected about you, the categories of sources from which it was collected, the business purpose for collecting or “selling” the information, and the categories of “third parties” to whom we disclosed or “sold” that information. You may also request that we provide you in machine readable format a copy of the specific pieces of personal information we have collected about you in the past 12 months. You may make a request to know up to two times in a 12-month period, subject to limitations described in the law. For a list of general categories of information that we have collected and shared in the past 12 months, see the tables above in the “What We Collect and Why” and “How We Share Your Data” sections.
RIGHT TO DELETE. You may request that we delete any personal information that we have collected from you. However, the law exempts certain information from deletion. For example, we may keep information necessary for security and fraud detection. We also may keep information needed to provide you goods or services. For example, if you ask us to delete your data but retain your loyalty account, we will keep the information we need to continue providing you loyalty benefits. When we respond to your request to delete, we will explain what (if any) information we have kept and why. Please note that the law does not consider anonymized or pseudonymized information to be “personal information,” and we may “delete” your information by anonymizing or pseudonymizing it.
NON-DISCRIMINATION. You have the right to be free from discrimination for using these rights. We will not deny you goods or services, charge you different rates, or give you different discounts because you used one of these rights.
HOW TO MAKE A REQUEST. You may make a request to know or delete by emailing firstname.lastname@example.org or by calling 208-720-3535. When you make a request, we will take steps to verify your identity before responding. This is to protect your information. We will ask you to provide us your email and physical address. If you maintain an account with us, these must match the addresses connected to your account.
AUTHORIZED REPRESENTATIVES. You may also designate an authorized representative to make data subject rights requests on your behalf. We will require verification that you did in fact authorize the representative. Unless the law requires otherwise, your authorized representative must provide contact details for you. We will contact you to confirm that you authorized the representative. Once you confirm, we will promptly respond to the rights request.
CONTACT FOR MORE INFORMATION. If you have questions please contact email@example.com.
RIGHT TO OPT OUT OF “SALE” OF PERSONAL INFORMATION If you are a California resident, you have the right to opt out of the “sale” of your personal information to “third parties.”
Sale is defined very broadly. The law defines “sale” more broadly than you might think. It doesn’t just include the exchange of data for money. Instead, it covers any transfer of personal information to a “third party” in exchange for “other valuable consideration.”
We do not transfer your information to third parties in exchange for money and we will not do so. However, we do transfer personal information to certain third parties in order to operate our business (for example, to market our products and services). It is possible that someone could claim that this transfer was in exchange for “other valuable consideration.” We want to be careful with and respectful of your information. Therefore, if you opt out, we will not transfer your information to any “third party” except as explained below (and allowed by law).
Opting out may have impacts you don’t expect. Any transfer of data to a “third party” may be considered a “sale” of data. The law considers any other business a “third party” unless that business agrees to specific contractual provisions. We try to get all of the businesses to whom we send information to add this special language to their contracts with us. But not everyone will or can agree to those terms.
As a result, if you opt out of the “sale” of data, we will not be able to send data to some of our business partners. That may mean that, after you opt out, you may not receive all of the marketing and other information you are accustomed to receiving from us. In the extreme, if one of our critical partners cannot agree to the special contract language, and is considered a “third party”, it is possible that some features of our web site or other services may not work for you after you opt out.
In addition, California law prevents us from asking you to “opt in” for a year after you “opt out.” We are allowed to tell you, however, if a specific transaction requires a transfer of data to a third party. We may alert you if a transaction requires a transfer to a third party so that you can opt in if you would like to continue with the transaction.
Minors. We do not “sell” the data of people under 16, and do not intend to collect data related to people who are under 13.
Exceptions to the opt out. The law creates several exceptions that are important for you to be aware of.
We are allowed to transfer data to a “service provider” even if you opt out. The law does not consider that kind of transfer to be a “sale.” A service provider is a business that agrees not to use your information for any purpose other than providing the services specified in our contract. For example, we transfer data to business partners to provide data security and detect fraud. Those businesses are “service providers.” Even if you opt out, we will continue to transfer data to our service providers.
We are also allowed to transfer your data to a third party where you direct the transfer or direct us to interact with the third party. For example, if you direct us to use a specific payment method to pay for your order, even if you have opted out, we will still transfer the data necessary to process your order.
Collecting information and using it ourselves is not a “sale.” Opting out of the “sale” of your data does not prevent us from continuing to collect and process your personal information. You can learn more about how and why we collect personal information at our Notice of Collection.
The “opt out” only applies to “personal information.” This is information that is or is capable of being linked to you. We use anonymization and pseudonymization to protect privacy. That data is not “personal information.” Opting out will not limit our transfer of that data to third parties.
Technical limitations on opt out. Please note that there are technical limits to our ability to identify data related to you and, if you opt out, to prevent the “sale” of that information to other parties. Where we can reasonably determine that information relates to you and you have opted out, we will not “sell” it to “third parties” (except as allowed by the law). However, we may not be able to determine that information relates to you. In that case, the information may be “sold” to a third party.
Opting out is not unsubscribe. Opting out of the “sale” of personal information will not prevent you from receiving marketing messages from us. If you wish to unsubscribe from our emails, please follow the unsubscribe link in one of our emails. If you wish to unsubscribe from text messages, please follow the unsubscribe process for the program you opted into.
HOW TO OPT OUT. If you would like to opt out of the “sale” of your data, you may email us at firstname.lastname@example.org, or you may call us at (208)720-3535.
If you want to opt out using email or phone number, you will need to follow more steps. If you want to opt out an email address that is different from the email on your account, you will need to use the email or toll-free number to do so. To use the email or toll-free numbers to opt out, you or your authorized representative will need to provide us the email address you wish to opt out. We will then send a message to that address. You must reply from that email address to complete the process. This extra step is to authenticate you and prevent fraud and abuse. If you want multiple email addresses opted out, you must provide each address to us. This is because we have no reasonable way to use a single address you give us to link to other addresses you may have.
The most complete way to opt out is to use the “opt out” button and then follow the prompts to email us the email addresses you would like opted out. If you do, we will set a cookie on your device to facilitate your opt out. That cookie will enable us to identify you if you return and allow us to prevent data from being “sold”. If you delete the cookie or return using a different device or browser, we will not be able to connect the session to your opt out and will not be able to prevent the “sale” of the data.
After you click the “opt out” button, if you want to opt an email address out, you must follow the prompts and provide us the address. In the alternative, you may email us or call our phone number. In either case, you or your authorized representative will need to provide us the email address you wish to opt out. We will then send a message to that address. You must reply from that email address to complete the process. This extra step is to authenticate you and prevent fraud and abuse. If you want multiple email addresses opted out, you must provide each address to us. This is because we have no reasonable way to use a single address you give us to link to other addresses you may have.
If you email us or call our phone free number, we will have no way of setting a cookie on your device. This will limit our ability to prevent the “sale” of data. For this reason, the opt out button is the most complete way to opt out of the “sale” of data.
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