PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Last Modified: January 1, 2020

Introduction

This Privacy Notice for California Residents supplements the information contained in Old World Industries’ general Privacy Policy and its Employee Privacy Policy and applies solely to those who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice applies to Old World Industries, LLC and any of its affiliate companies.

The CCPA temporarily provides an exemption for the application of certain provisions regarding employment-related personal information collected from California-based employees, job applicants, contractors or similar individuals (“Employee Exemption”) and personal information reflecting a written or verbal business-to-business communication (“B2B personal information”). Accordingly, this Notice only applies to the extent of the currently applicable provisions of the CCPA and your rights may be different if you fall under either of these exemptions.

 

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, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • 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 its consumers within the last twelve (12) months:

 

 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES*
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES*
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES*
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)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES*
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

*These categories of information are only collected (when applicable) from our employees, job applicants, or contractors. These categories of information are not collected from consumers.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you complete a rebate form, submit a product claim, or submit a “contact us” request on our website.
• Indirectly from you. For example, from observing your actions on our websites.

For more information, please see Old World’s Privacy Policy in the section entitled, “What Type of Information Do We Collect and How Do We Collect It?”

 

Use of Personal Information

For information on how we use your personal information, please see Old World’s Privacy Policy in the section entitled, “How Do We Use Your Information?”

 

Sharing Personal Information

We will not sell or rent your personal information, except in the event all or a part of our business is merged, sold or reorganized. Old World has not sold or rented any personal information in the past 12 months.

For more information on how we share your personal information, please see Old World’s Privacy Policy in the section entitled, “How Do We Share Your Personal Information?”

The following are categories of third parties with whom we may share your personal information for a business purpose:

• Service providers;
• Data aggregators;
• Advertisers;
• Affiliates;
• Partners;
• Parent of subsidiary organizations;
• Social media companies;
• Internet cookie data recipients, like Google Analytics.

 

Disclosures of Personal Information for a Business Purpose

In the preceding 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;
• Category D: Commercial information;
• *Category E: Biometric Information;
• Category F: Internet or other similar network activity;
• +Category G: Geolocation data;
• +Category H: Sensory data;
• *Category I: Professional or employment-related information;
• *Category J: Non-public education information;

*These categories of personal information are only collected for our employees, job applicants and contractors, if applicable, and are only shared with service providers, data aggregators, affiliates and parent and subsidiary organizations.

+These categories of personal information are only disclosed (if applicable) to provide further services to you, such as a mobile application that allows you to find a location nearest to you, or a voice-activated option on an application.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Please note that for employees and B2B personal information, the following rights are currently exempt from the CCPA and may not apply to you. You are welcome to contact us and we will use commercially reasonable efforts to address your concerns, but we cannot assure you of strict compliance with the rights and choices articulated below.

 

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 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 disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
•  

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 services provider(s) to:

• 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract 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.

 

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 by phone or email directed to the following:

Old World Industries, LLC
3100 Sanders Road, Suite 500
Northbrook, Illinois 60062
Attn: Office of the Chief Legal Officer
Phone: (847) 559-2224 or (847) 559-2007

If you use any of our services that require you to form an account with us, you can access your information in the profile section of the website or mobile application. You may also request to delete your personal information if there is a “contact us” feature located with your specific web portal or mobile application.

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; and
• 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.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, 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.

 

Personal Information Sales Opt-Out and Opt-In Rights

Old World is not in the business of selling or renting personal information, does not intend to sell or rent personal information, and has not in the past 12 months sold or rented any of your personal information. Accordingly, we do not have a mechanism to opt out as we do not sell personal information.

 

Non-Discrimination

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.

 

How Will I Know if this Notice Changes?

The Notice may change from time to time. Please check our Notice periodically for changes. We will provide additional notice by emailing you at the email address that you provided of any material updates. We will post the date our Notice was last updated at the top of the Notice.