Dude Products, Inc.
Effective Date: February 14, 2021
Dude Products, Inc. (“Dude Products,” “we,” “us” or “our”) values your privacy and is committed to protecting your Personal Information (as defined below). Dude Products delivers high-quality wipes and grooming supplies (“Products”).
- What Information Do We Collect About You and Why?
This Policy covers our treatment of personally identifiable information. Such information may include name, mailing address, email address, telephone number, and other information which identifies you as a specific individual (“Personal Information”). Please see additional information below on the information we collect. For this Policy the definition of “Personal Information” is the definition under the state, country, or other law applicable to the person whose data is collected; however, for California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information. Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
We may also collect Personal Information from you through means other than our Site. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It may also include emails, text messages, or other electronic communications that you send to us separate from our Site or by way of our third party service providers. However, if we combine the Personal Information we collect from you outside of our Site with Personal Information that is collected through our Site or by another means as described above, the Policy will apply to the combined information, unless specifically disclosed otherwise.
Other than as stated herein, this Policy does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Site. We are not responsible for the practices of sites linked to from the Services, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.
We collect several categories of Personal Information from and about you as summarized in the following table:
Specific Items of Personal Information
first and last name, user name, email address, postal address, unique personal identifier, e.g., device identifier (e.g., mobile device ID), IP address, customer/account name or number, phone number, cookies, beacons, pixel tags, mobile ad identifiers
products/services purchased, purchasing/consuming history or tendencies
Internet or other electronic network activity
browsing, session, interaction, and search history related to our Site
physical location or movements
Professional or employment information
email address that identifies you (e.g., firstname.lastname@example.org versus email@example.com)
Inferences drawn from any of the above to create a profile of a consumer
a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Information You Provide Us.
The Personal Information we collect through our Site, or from our distributors, resellers, representatives, business partners, or service providers may be obtained as part of the following:
- Information that you provide by filling in webforms on our Site. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Site, products, or Services, or otherwise communicating with us.
- Records and copies of your correspondence (including email addresses), if you contact us
- Registering for an event
- Your responses to surveys that we or our service providers might ask you to complete for research purposes
- Your search queries on the Site
- In stores (parent, subsidiary and affiliate brands)
- On mobile applications (parent, subsidiary and affiliate brands)
- When communicating with customer service/support
- Through participation in loyalty/rewards programs
- Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
- Data suppliers (e.g., companies that provide demographics and other information regarding consumers)
- Online advertising companies
- Fulfillment and delivery service providers
- Social media companies
- Other service providers
- Responding to employment opportunities
Information We Collect Automatically.
We may also use automated devices and applications, such as Google Analytics and Facebook Insights, to track usage of our Site. We may use the information gathered through these methods in aggregated form to analyze ways to improve our Site. This information may also be associated with your username or email address and may be combined with other information, including Personal Information that we collect about you.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Site; (c) speed up your searches; and/or, (d) recognize you when you return to our Site.
- How Long Do We Keep This Information?
The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Site. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you.
We may retain De-Identified Personal Information for as long as we deem appropriate.
- What About Cookies and Other Tracking Mechanisms?
Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
Third Party Cookies. We may also engage third parties to track and analyze non-personally and personally identifiable Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. We do not authorize nor allow, to the best of our knowledge, the third parties we engage to use the information we provide for their own personal use.
Disabling Cookies . Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable their web browsers’ ability to accept cookies will be able to browse the Site; however, some Site features may not function if you disable cookies.
Essential Cookies. These cookies are essential to allow you to browse our Site and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
Functionality Cookies. These cookies enable our Site to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Site corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Site. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
Local Storage Cookies. Certain features of our Site may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Site. These server logs may include information such as which pages of the Site you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Site. These log files are generally deleted periodically.
Information We Collect from Third Parties
We may collect information that others provide about you when you use the Site, or obtain information from other sources and combine that with information we collect through the Site.
- Third Party Services. If you link, connect, or login to your account with a third party social media service (e.g., Facebook, Google, Instagram, Yelp, etc.), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Site through partnerships, or about your experiences and interactions from our partner ad networks.
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) in order to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. In addition, you cannot control, delete, or disable the acceptance of Flash LSOs through your browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “ Global Storage Settings Panel“ and follow the instructions. To see the Flash LSOs currently on your computer, choose “ Website Storage Settings Panel“ and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Site Analytics. As noted, we may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site, performance and user experiences.
Third-Party Ad Networks. We may use third parties such as network advertisers to serve advertisements on our Site. Please see the section “What About Third-Party Ad Networks?” below for additional information about our practices and your choices with regard to receiving such advertisements.
- What About Third-Party Ad Networks?
You may opt-out of many third-party ad networks. The Network Advertising Initiative (“NAI”) provides information on this, and your choices regarding having this information used by NAI members, including how to “opt-out” of third-party ad networks operated by NAI members. Also, About Ads has information about opting out of behavioral advertising and your choices regarding having information used by About Ads member companies, including how to “opt-out” of third-party ad networks operated by About Ads members. Opting out of one or more NAI members or About Ad members (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you, but it does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or About Ad opt-out may no longer be effective.
- How Do We Use Your Information?
We use the information that we gather about you for the following purposes:
- To present our Site and its contents to you.
- To provide you with information and respond to your questions on products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.
- To provide you with the products, services, or information that you have requested.
- To process transaction payments, including, but not limited to, product and/or service fees, subscription fees, professional fees, membership dues, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number).
- To process discounts, offers, loyalty rewards, and/or rebate requests, forms, and applications and coordinate with the manufacturer, retailer and/or wholesaler
- To provide you with notices about your account, including expiration and renewal notices.
- To notify you about information regarding or changes to our Site, our policies, terms, or any products or Services we offer or provide, or regarding your account
- To process your account application and any changes to your account information.
- To process Personal Information or other information that you submit through to us.
- To allow you to participate in interactive features on our Site.
- To contact you about our own and third-parties’ products and services that may be of interest to you.
- To provide access to restricted parts of our Site, e.g., areas accessible if you have a user account.
- To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests.
- For internal purposes, such as Site and system administration or internal audits and reviews.
- For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
- To operate, maintain, and provide to you the features and functionality of the Services.
- To provide statistics about the usage levels of the Site and other related information to our service providers.
- To notify you of data privacy incidents or provide you with legally required information.
- To contact you regarding a sweepstakes, contest, or promotion in which you have participated.
- To request your participation in ratings, reviews, surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.
- For examination or event registration, scheduling, event attendance, administration and related purposes.
- To fulfill any other purpose for which you provide Personal Information.
- In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.
The information we collect from you enables us to fulfill your request for our products, namely, to send you the wipes and/or other grooming products that you order and receive through your order. The information we collect is also used to send you administrative or account communication or content in which are essential to your account. These communications are essential to the successful and effective functioning of your purchase therefore the sole remedy to opt-out is to cancel your order. You may cancel your order either by emailing a request to firstname.lastname@example.org. We also use this information to personalize and continually improve our Site.
We may use your Personal Information you provide us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to our doing this at any time by contacting us (see Contact Information/User Rights below).
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We use the information we collect about you to deliver the Services we offer, and to operate and improve our Site. Our services may include a Short Message Service (“SMS”) which may deliver up to two messages per day to your wireless device. We may use your information to contact you about your reservation, purchases, Site updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us.
With your permission, we may send text messages about our store, new products, and other updates. Updates include Checkout Reminders. Webhooks will be used to trigger the Checkout Reminders messaging system.
Social Media Plugins
We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Site. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.
For example, when you visit our Site, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Site with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Site to your Facebook profile. This allows Facebook to assign your visit to our Site to your user account. Please note that as provider of the Site, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Site to your Facebook user account, please log out of your Facebook user account.
If you do so, you authorize us to access certain social media site account information, such as your public social media profile (consistent with your privacy settings in the social media site), your email address, interests, likes, gender, birthday, education history, relationships, interests, current city, photos, personal description, friend list, and information about and photos of your social media site friends who might be common social media site friends with other users. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s policy, and not by our Policy. You can find the policy for a platform on their website.
- When and How Does Dude Products Share Information It Receives?
We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:
- Data storage or hosting providers for the secure storage and transmission of your data
- Database and software service providers for the management and tracking of your data
- Technology providers who assist in the development and management of our Site
- Identity management providers for authentication purposes
- Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
- Payment solution providers for the secure processing of payments you provide to us
- Manufacturers, retailers, and wholesalers for submission, processing, and management of rebates, discounts, offers, loyalty rewards, and the like
- Outbound call center providers, who may perform outreach on our behalf regarding our products and Services
- Fulfillment and shipping vendors for the fulfillment of our Products and Services
- Survey and research providers who perform studies on our behalf
- Publishers and learning providers who develop products on our behalf
- Advertising partners, including social media providers, for the delivery of targeted advertisements
We do not sell or rent our users’ Personal Information to third parties for their own marketing or other purposes. As discussed in this Policy and described below, we may share your information, including Personal Information, with third parties to assist us with our own marketing efforts and to assist us in operating our Site and fulfilling your Membership.
We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), and processing credit card payments. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
Your Personal Information may be maintained and processed by our affiliates and third party vendors, service providers, contractors or agents in the US or other jurisdictions. These organizations are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. For additional information on the way in which these organizations treat your Personal Information, you may contact us as set out below.
You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”),, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to your Personal Information and other information and your consents, with or without notice to you and without your further consent.
Except as otherwise described in this Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Site or our products and services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Site, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Policy.
Disclosure of De-Identified Personal Information.
We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Site. It may be utilized to measure the number of visits to our Site, average time spent, number of pages viewed and to monitor various other Site statistics. This monitoring helps us evaluate how visitors use and navigate our Site so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose. We may disclose, sell, rent, etc., your De-Identified Personal Information to third parties and we may receive valuable consideration for doing so.
Third Party Links.
Our Site may contain links to other third party websites. Any access to and use of such linked websites is not governed by this Policy, but, instead, is governed by the privacy policies of those third party websites, and we are not responsible for the information practices of such third party websites.
- Data Transfer/Access Outside of the United States
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
- How Secure Is Information About Me?
We have implemented commercially reasonable technical, physical and organizational safeguards to protect Personal Information in our custody or control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, including, where appropriate, password protection, encryption, SSL, firewalls, and internal restrictions on who may access data to protect our Site. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a password that nobody else knows or can easily guess, and keeping your password private.
We have Personal Information retention processes designed to retain Personal Information of consumers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Site or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
- Can I Access and Modify My Personal Information?
You have the right to access, update, and correct inaccuracies in your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may access and modify certain Personal Information that you have submitted emailing or writing to us at the contact information set out below. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.
Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
- Children Under 16
Our Site is not designed for children under 16. We do not knowingly collect information from children under 16. If we discover that a child under163 has provided us with Personal Information, we will delete such information from our systems.
- Privacy Notice for California Residents
The following in this section applies only to California residents.
California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here):
CalOPPA applies only to companies which collect Personal Information of California residents.
How We Respond to Do Not Track Signals.
CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, see www.donottrack.us. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. Visitors can visit our Site anonymously by adjusting the settings in your browser.
Third-Party Behavioral Tracking. We do not allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click or browsing patterns.
California Consumer Privacy Act of 2018 (“CCPA”, available here): If you are a California resident (occasionally referred to as “Consumer”), California law provides you with additional rights regarding our use of your Personal Information. For purposes of this California Consumer Privacy Notice and only for California residents, the term Personal Information means “personal information” as defined under CCPA.
This “Privacy Notice for California Residents” section does not apply (at least until January 1, 2021) to the Personal Information of California residents that we collect:
- which is reflecting a written or verbal communication or a transaction between us and you, where you are acting as an employee, owner, director, officer, or contractor of a company or government agency and whose communications or transaction with us occurs solely within the context of our conducting due diligence regarding, or providing or receiving a product or service to or from such company or government agency; or,
- in the course of your acting as a job applicant to or an employee of our company to the extent that your Personal Information is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of our company.
California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information (but which is inapplicable to us because we do not sell your Personal Information).
The categories of your Personal Information we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the categories of Personal Information are or may be used is described above in the section entitled “How We Use Your Information” and in other sections of this Policy.
No Sale of Personal Information
WE DO NOT SELL (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION, PERIOD.
Right To Access to Specific Information
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, 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) and provide a copy to you in an electronic or paper format.
- If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Right
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, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies (as described below).
As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.
We may deny your deletion request if retaining the information is necessary for us or our Service 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, 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.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal, regulatory or law enforcement 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 sending an email to us at email@example.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. 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. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor's identity or authority to make the request.
Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).
Response Timing and Format
We will confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), 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.
Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.
We will not discriminate against you simply for your 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 by refusing to gran discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or,
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Site or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Site and our Products and services, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
- Changes to This Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check our Policy website page periodically. We will post any changes to our Policy on our Site, and the revised version will be effective on posting.
- How to Contact Us About Privacy
If you have questions about the privacy aspects of our Site or would like to make a complaint, please contact us at firstname.lastname@example.org or: Dude Products, Inc., 3501 N Southport Ave., #476, Chicago, IL 60657, Attn: Privacy Department.