Last Updated on: 05/20/2021
SECTION 1 - INFORMATION WE COLLECT
Our business collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information” or “PI”). In particular, our business collects and has collected the following categories of PI from consumers within the last twelve (12) months:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
E. Biometric information.
F. Internet or other similar network activity.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
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)).
K. Inferences drawn from 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Shine Armor obtains the categories of PI listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
SECTION 2 - USE OF PERSONAL INFORMATION
We may use or disclose the PI we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information.
- If you share your name and contact information to request a price quote or ask a question about our products or services, we will use that PI to respond to your inquiry.
- If you provide your PI to purchase a product or service, we will use that information to process your payment and facilitate delivery.
- We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your PI or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Shine Armor assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PI held by Shine Armor about our Website users is among the assets transferred.
Shine Armor will not collect additional categories of PI or use the PI we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SECTION 3 - SHARING PERSONAL INFORMATION
Shine Armor may disclose your PI to third parties for business purposes. When we disclose PI for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that PI confidential and not use it for any purpose except performing the contract.
We share your PI with the following categories of third parties:
- Service providers.
- Data aggregators.
- Data analytics providers.
- Advertising networks.
SECTION 4 - DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE AND SALES
In the preceding twelve (12) months, Shine Armor has disclosed the following categories of PI for a business purpose:
- California Customer Records personal information categories.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Inferences drawn from PI.
The CCPA considers many common transfers of PI, such as the sharing of your IP address with certain analytics or advertising providers, to be a “sale.” In this sense, during the preceding twelve (12) months, Shine Armor has sold the following categories of PI to data analytics providers and advertising networks:
- California Customer Records personal information categories.
- Internet or other similar network activity.
- Geolocation data.
SECTION 5 - YOUR CALIFORNIA PRIVACY RIGHTS
As a California consumer, you have the right to request that we disclose what PI about you we collect, use, disclose, and sell. More specifically, you have rights to the following without charge. Please note we have included information about your rights and certain limitations on these rights under the CCPA to help you understand your rights, however these statements are for informational purposes only, not exhaustive, and your rights may be more limited under applicable law or regulation.
Right to Know
Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to know the categories of PI we collected about you in preceding twelve months; categories of sources of PI we collected about you; purposes for which PI was collected or sold; categories of third parties with which PI is shared; categories of PI sold in preceding twelve months including to which categories of third parties; categories of PI disclosed in preceding twelve months including to which categories of third parties; and access to specific PI we have collected and retained about you in a portable format.
We will not retain any PI about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained, nor will we reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered PI.
Right to Deletion
Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your PI from our records, and to have us direct our service providers to delete your PI from their records.
We are not required to, and reserve our right not to, delete your PI it if is necessary to complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; comply with an existing legal obligation; and otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out of the Sale of Personal Information
Under the definition of “sale” provided by California law, we sell PI that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household to third parties. We do not sell PI for money. We do however transfer PI to third parties for advertising and marketing purposes such as providing you advertisements elsewhere on the Internet for Shine Armor products in which you may be interested.
You have the right to opt-out of the sale of your PI. If you exercise your right to opt-out of the sale of your PI, we will refrain from selling your PI, unless you subsequently provide express authorization for the sale of your PI.
Right to Freedom from Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the California Consumer Privacy Act. This means we cannot on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
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.
SECTION 6 - HOW TO EXERCISE YOUR CALIFORNIA RIGHTS
Unless otherwise specified, to exercise any of your rights described in this Statement, please complete a consumer request form available here; call us at +1 (408) 528 2764; or submit your request to us at the following email address: firstname.lastname@example.org.
To opt-out of the sale of your PI, visit our homepage and click on the Do Not Sell My Personal Information link, or click here.
In order to verify your request, you will need to provide us with enough information to identify you (e.g., your full name, address, and customer or account number), proof of your identity and address, and a description of what right you wish to exercise along with any information to which your requests relates.
You may also designate an authorized agent registered with the California Secretary of State to make a request under the California Consumer Privacy Act on your behalf. You may also make a verifiable consumer request on behalf of your minor child. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require you verify your own identity with us directly.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Making a verifiable consumer request does not require you to create an account with us.
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 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 reserve our right not to fulfill a request if we cannot verify that the person making the request is the person about whom we collected information or someone authorized to act on such person’s behalf. Any PI we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. You will not have to pay a fee to access your PI or exercise any other rights described herein. However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive. 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. You may only make a data access or data portability request twice within a 12-month period.
SECTION 7 - CHANGES TO OUR CALIFORNIA NOTICE
Shine Armor reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Notice on the Website and update the California Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
SECTION 8 - CONTACT INFORMATION
If you have any questions or comments about this California Notice, the ways in which Shine Armor collects and uses your information described above, or your choices and rights regarding such use, please do not hesitate to contact us via the following:
- Email: email@example.com
- Phone: +1 (408) 528 2764
Individual customers who reside in California and have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at firstname.lastname@example.org with the subject “CALIFORNIA STL REQUEST”. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
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