Last revised on, and effective as of May 10, 2021
A. Overview of California Privacy Rights
This document (this “California Privacy Policy”) (i) describes the rights of California residents (“Consumers”) under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”); (ii) describes our practices regarding the collection, use, and disclosure of the Personal Information of Consumers, except to the extent such Personal Information is exempt from the CCPA or otherwise does not constitute “Personal Information” as defined by the CCPA; and (iii) explains how Consumers may contact us to exercise those rights. This California Privacy Policy supplements our Privacy Policy and applies only to the Personal Information of Consumers. In the event of any inconsistency or conflict of any kind between the provisions of this California Privacy Policy and the provisions of our Privacy Policy or any other policy, statement or notice of ours, this California Privacy Policy shall control as to Consumers and their rights under the CCPA.
For purposes of this California Privacy Policy, the term “Personal Information” shall have the meaning set forth in the CCPA. Other terms defined in the Privacy Policy that are not defined in this California Privacy Policy shall have the meaning given to them in the Privacy Policy.
B. Consumer Rights
This section describes certain rights of Consumers under the CCPA. For information on how Consumers may contact us to exercise these rights, please see the section below entitled, “How to Submit a Request”.
-
Right to Know. A Consumer has the right to request that a business disclose what Personal Information it collects, uses, discloses or sells with respect to such Consumer. Specifically, a Consumer may request that a business that collects Personal Information about the Consumer disclose to the Consumer the following:
- The categories of Personal Information it has collected about that Consumer
- The categories of sources from which the Personal Information is collected
- The business or commercial purpose for collecting or selling Personal Information
- The categories of third parties with whom the business shares Personal Information
- The specific pieces of Personal Information it has collected about that Consumer
A Consumer may request that a business that sells the Consumer’s Personal Information, or that discloses it for a business purpose, disclose to that Consumer:
- The categories of Personal Information that the business collected about the Consumer
- The categories of Personal Information that the business sold about the Consumer and the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold
- The categories of Personal Information that the business disclosed about the Consumer for a business purpose
-
Right to Request Deletion. A Consumer has the right to request that a business delete any Personal Information about the Consumer which the business has collected from the Consumer. If it is necessary for us to maintain the Personal Information for certain purposes, we are not required to comply with a Consumer’s deletion request. If we determine that we will not delete your Personal Information when you request us to do so, we will inform you and tell you why we are not deleting it.
-
Right to Opt-Out of Sale of Personal Information. A Consumer has the right to direct a business that sells Personal Information about the Consumer to third parties not to sell the Consumer’s Personal Information. We do not sell any Personal Information of Consumers.
-
No Discrimination. A Consumer has the right not to be discriminated against because the Consumer exercised any of its rights under the CCPA.
C. How to Submit a Request
To exercise the rights described above in this California Privacy Policy, you must submit a verifiable Consumer request to us by contacting us at 877-319-3757 or by submitting a request online here and providing the requested information.
You may submit a request as frequently as you would like, but we are not required to respond to requests to provide Personal Information to you more than twice in any 12-month period.
To submit a verifiable Consumer request, you will be asked to provide certain information to help us verify your identity, including your name, email address, phone number or information regarding your previous interactions with us. The information we ask you to provide to initiate a request may differ depending upon the type of request; the type, sensitivity and value of the Personal Information that is the subject of the request; and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors. As required by the CCPA, in response to a Consumer request, we will never disclose a Consumer’s social security number, driver’s license number or other government-issued identification number, financial account number, account password, or security questions and answers, as applicable.
You may make a verifiable Consumer request on behalf of your minor child. You may also designate an authorized agent to make a request on your behalf. If you designate an authorized agent to make a request on your behalf, we reserve the right to require verification of your authorized agent’s identity and authority, which may include, among other things, a requirement that your authorized agent provide us with (i) your written authorization permitting the authorized agent to submit a request on your behalf or (ii) a duly executed power of attorney permitting the authorized agent to submit a request on your behalf. If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. 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. Categories of Personal Information that We Collect
Depending on how a Consumer interacts with us and our third-party retailers, we may collect the categories of Personal Information described below. The nature of both the categories and the specific pieces of Personal Information that we may collect about a Consumer will vary depending on the nature and purpose of our interactions and manner in which we received your Personal Information.
We have collected the following categories of Personal Information about Consumers in the 12 months prior to the effective date of this California Privacy Policy:
| 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. | NO |
| 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 |
| i. Professional or employment-related information. | Current or past job history or performance evaluations. | 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)). | 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. | NO |
| k. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
E. Sources of Personal Information We Collect
We collect the Personal Information described above from the following categories of sources:
- From you directly, including through emails, phone calls or via customer support inquiry via the Sites or Services
- From affiliates and partners
- From your browsing activity on our affiliates’ or partners’ websites
- From service providers, including marketing partners, data providers who provide us with information about individuals in order for us to understand who may be interested in our products and/or services, data aggregators, analytics providers and companies that help us provide our Sites to you
- From third-party retailers who send us your Personal Information in order to process and ship the products that you purchased from them, which ship from our warehouses
F. Business Purposes for Personal Information We Collect
We collect the Personal Information described above for a variety of business purposes. Generally, we collect and use such Personal Information to provide our products and Services, to communicate with you in response to your queries and to ensure the uninterrupted and secure operation of our business. In particular, we use the Personal Information:
- To provide our products and Services to you and activities related to our provision of such Services, including maintaining or servicing accounts, providing customer service, and processing transactions that you initiate through third-party retailers, which are shipped from our warehouses
- To provide you with information about new products or services, or products or services related to those you previously purchased
- To improve, upgrade or enhance our products, Services and advertising or to develop new products or services
- To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- To debug to identify and repair errors that impair existing functionality
G. Categories of Third Parties with Whom We Share Personal Information We Collect
We do not share your Personal Information with any third parties other than in accordance with this California Privacy Policy. To the extent permitted by applicable law, we may share your Personal Information described above with the following categories of third parties:
- Service Providers. We may share your Personal Information with third-party service providers to assist us in providing the Sites and Services to you, including service providers that host our databases, infrastructure, or provide other cloud-based services; assist us with communicating with you on the Site; provide analytics services to help us understand the activity on the Site; and assist us with the financial, regulatory and legal aspects of our business
- Retailers. Certain third-party retailers send us your Personal Information in order to process and ship the products that you purchased. We may confirm your Personal Information with the retailer who received the order; however we do not share your Personal Information with any other retailer.
- Affiliates and Partners. We may share your Personal Information with affiliates and partners.
- Courts or Government Entities. We may share your Personal Information with courts or governmental entities as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process.
- Business Transactions. We may share your Personal Information with actual or potential acquirors or other parties to a transaction in the event of an asset sale, spin-off, merger or similar corporate transaction involving us or one of our business units.
H. Sales of Personal Information
We do not sell, and have not sold in the 12 months prior to the effective date of this California Privacy Policy, Personal Information about Consumers.
I. Disclosure of Personal Information for a Business Purpose
We have disclosed Personal Information about Consumers for a business purpose in the 12 months prior to the effective date of this California Privacy Policy. In particular, we have disclosed the following categories of Personal Information about Consumers for a business purpose in the 12 months prior to the effective date of this California Privacy Policy:
- Name, postal address, telephone number, Internet Protocol address, email address.
J. Contact Us
If you have any questions about this California Privacy Policy, please call us at 877-319-3757 or contact us.
