CA Consumer Privacy Act

Your California Privacy Rights

Effective January 1, 2020

Subject to certain limits under the California Civil Code, if you are a California resident, you have the right to submit certain requests relating to your personal information as outlined below.

Categories of personally identifying information that we collect include the following: name, postal address, email address, phone number, and purchase history, including specific items you have purchased; browsing history and search history, including your IP address, and interactions with electronic communications; preference data that you have shared, or that we have derived from your purchase and browsing history.

In addition to the above, we may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you.

We do not sell your personal information to third parties. We may, however, share your personal information with third-party service providers in accordance with the business purposes set out in this Privacy Policy.

Specific Rights

California residents are entitled to (1) request more information regarding the categories and specific pieces of personal information we collect; and (2) request the deletion of their personal information. Our policies with respect to each of these rights are discussed below. This section also states our policy on the verification of identity for purposes of requests for more information or deletion of information, which is required under law.

Right to Request More Information

You may request more information regarding the following, to the extent applicable:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we have collected your personal information.
  • (your right) The business or commercial purpose as to why we collected your personal information.
  • The categories of third parties with whom we shared your personal information in the past 12 months.
  • The specific pieces of personal information we have collected about you.
  • The categories of personal information that we have shared with third parties about you for a business purpose.
  • A list of all third parties to which we have disclosed your personal information (as defined under California Civil Code Section 1798.83(e)) during the preceding year for third-party direct marketing purposes.

 

Right to Request Deletion of Your Personal Information

Upon your request and confirmation of your identity, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers with whom we shared your personal information also to delete your personal information from their records. There may be circumstances where we (or our service providers) cannot delete your personal information. For example, if we need to: (A) retain your personal information to complete a transaction or provide goods or services; (B) detect security incidents; (C) protect against unlawful activities; (D) identify, debug or repair errors; (E) comply with a legal obligation (for example, to comply with warranty return obligations) or (F) to document activities and communications with you, including any specific request related to this policy.

Verification of Requests for Further Information or to Delete Information

Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.

We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.

The following generally describes the verification processes we use:

  • Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
  • Verification for Non-Account-holders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
    • For requests to known categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
    • For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request. We will maintain all signed declarations as part of our records.
    • For requests to delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
  • Verification by Authorized Agent. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described below.

If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.

Right to Non-Discrimination for the Exercise of Your California Privacy Rights

If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing goods or services to you, charge you different prices or provide a different level or quality of goods and services to you unless those differences are related to the value of your personal information.

Changes to This Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of our website and/or your choice to continue purchasing goods or services from us after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.