Last Updated: March 11, 2020
Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual.
Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or by application service providers that we use to support our business.
Collection or Disclosure of Personal Information
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, only the following categories of Personal Information relating to California residents covered by this disclosure:
- Commercial information, such as transaction information and purchase history;
- Identifiers, such as name, postal address, email;
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
- Personal information, as defined in the California safeguards law, such as contact information and financial information;
- Internet or network activity information, such as browsing history and interactions with our website;
We do NOT collect or disclose to third parties any of the following categories of Personal Information:
- Characteristics of protected classifications under California or federal law, such as sex and marital status;
- Biometric information, such as fingerprints and voiceprints;
- Geolocation data, such as device location and Internet Protocol (IP) location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, such as student records and directory information; and
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Application Service Providers that host the websites and applications we use to support our operations and communications with our business partners.
- Product suppliers and vendors that supply and ship the products we sell
- Consumer Data Resellers, media companies and other third parties
- Mobile App Activity,
- Phone and text messaging services.
- Public record sources (Federal, State or Local Government Sources).
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:
- Service providers who provide services such as website hosting, data analysis, web traffic analysis, information technology and related infrastructure, customer service, text messaging or email delivery, auditing, marketing and marketing research activities, communication infrastructure and storage.
- Product suppliers who provide services such as order fulfillment, shipment, warranty and product returns.
- Media companies and social media providers who promote the Company and products to their audiences, customers and other prospective buyers.
- Third parties who provide services such as payment processing, banking, legal expertise, tax expertise, customer research, customer analytics, consulting, notaries and auditors
- Other third parties who enable customers to conduct transactions online and via mobile devices.
- Government agencies as required by laws and regulations
- Third parties in connection with a merger, sale, or asset transfer.
- Other third parties for whom we have obtained your permission to disclose your Personal Information.
Use of Personal Information
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking research for technological development, marketing or demonstration.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)
Sale of Personal Information
We do not send Company or marketing information to you without your consent. A consent form for this purpose is provided on our website and presented at the time of a product purchase. You may opt-out from the receipt of additional marketing material from the Company at any time. We may sell or share your Personal Information with product suppliers, media companies, or other third parties for their direct marketing purposes. For purposes of this notice “sell or share” means the disclosure of Personal Information to a third-party for monetary or other valuable consideration. You may opt-out from the sell or share of your Personal information for our business partner direct marketing purposes. An opt-out form is provided at the time of collection of your information for this purpose.
We do not collect or sell Personal Information of minors under the age of 16.
Your California Privacy Rights
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected;
- the categories of sources from which the Personal Information was collected;
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- the specific pieces of Personal Information we collected about you;
- Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information may require additional information to verify your identity.
If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.
We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Calling (888) 406-9452
You may contact us with questions or concerns about this Disclosure and our practices by:
- Writing us at:
665 Commerce Drive
Fairfield, CT 06825
- Emailing us at firstname.lastname@example.org
Changes to This California Consumer Privacy Act Disclosure
We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.