Addendum for California Consumer Privacy Act

Last Updated: Sept 13, 2020

If you are a California “consumer” within the meaning of the California Consumer Privacy Act of 2018 (“CCPA”), this Addendum for California Consumer Privacy Act (“CCPA Addendum”) applies to you. The CCPA Addendum supplements our privacy policy (the “Policy”) and prevails over any conflicting provisions in the Policy.

This CCPA Addendum uses certain terms that have the meanings given to them in the CCPA, including:

  • “Personal Information,” which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

  • “Sell,” “selling,” “sale,” or “sold,” which means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information by us to another business or a third party for monetary or other valuable consideration.

1. Our Collection, Use, and Disclosure of Personal Information

A. Categories, Sources, and Purposes of Your Personal Information Collected or to Be Collected

The table below describes the categories of Personal Information (as listed in the CCPA) that we may collect, and have collected during the 12-month period prior to the effective date of this CCPA Addendum.

Category of Personal Information Collected Example
Identifiers Name, address, e-mail address, phone number, fax number, vehicle identification number, license plate number, field test video, information submitted through forms on our website (if they are identified or associated with you) and access data including cookies
Commercial information Products or services you purchased or own
Internet or network activity information Access data including access logs, web beacons (also known as pixels), cookies, etc.
Geolocation data GPS data

Business or Commercial Purposes. The business or commercial purposes for which the categories of Personal Information will be collected or used, or was collected or used during the 12-month period prior to the effective date of this CCPA Addendum, is as described in “4. Legal Basis for and Purpose of Processing Personal Data” in the Policy.

Categories of Sources. The categories of sources from which Personal Information was collected during the 12-month period prior to the effective date of this CCPA Addendum are as described in “3. How We Collect Your Personal Data” in the Policy.

B. Sharing of Your Personal Information

(A) Sale of Your Personal Information

The table below describes: (i) the categories of Personal Information (as listed in the CCPA) that we may have sold during the 12-month period prior to the effective date of this CCPA Addendum; and (ii) the categories of third parties to whom we have sold such Personal Information during the 12-month period prior to the effective date of this CCPA Addendum.

Category of Personal Information Sold Example Third Parties to whom Personal Information Was Sold in the Last 12 Months
Identifiers Access data including cookies Data analytics providers
Internet or network activity information Access data including access logs, web beacons (also known as pixels), cookies, etc. Data analytics providers

Business or Commercial Purpose. The following is a list of the business or commercial purposes for which Personal Information was sold during the 12-month period prior to the effective date of this CCPA Addendum:

  • Data analytics

Children’s Personal Information and Opt-In Right. We do not sell, and have not sold, the Personal Information of minors under 16 years of age without their affirmative authorization if we have actual knowledge of the individual’s age.

(B) Disclosure of Personal Information for a Business Purpose

The table below describes: (i) the categories of Personal Information (as listed in the CCPA) that we may have disclosed for our operational business purposes during the 12-month period prior to the effective date of this CCPA Addendum; and (ii) the categories of third parties to whom we have disclosed such Personal Information for our operational business purposes during the 12-month period prior to the effective date of this CCPA Addendum.

Category of Personal Information Disclosed Example Third Parties to whom Personal Information Was Disclosed in the Last 12 Months
Identifiers Name, address, e-mail address, phone number, and access data including cookies Our employees
Affiliates
Service providers including internet service providers, web analytics service providers, and cloud service providers
Internet or network activity information Access data including access logs, web beacons (also known as pixels), cookies, etc. Our employees
Affiliates
Service providers including internet service providers, web analytics service providers, and cloud service providers

2. Your Rights and Requests

If you are a California consumer, you have certain choices regarding your Personal Information, as described below:

  1. Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information we have collected, used, disclosed, and sold about you during the 12 months preceding your request:

    1. The categories of Personal Information we collected about you;

    2. The categories of sources from which we collected such personal data;

    3. The business or commercial purpose(s) for collecting such Personal Information about you;

    4. The categories of third parties with whom we shared such Personal Information;

    5. The specific pieces of Personal Information we have collected about you; and

    6. The categories of Personal Information we sold with regard to you and the categories of third parties to whom such Personal Information was sold.

  2. Deletion: You have the right to request that we delete certain Personal Information we collected from you.

  3. Sale: You have the right to opt-out of the sale of Personal Information.

How to Submit a Request. To make an access or deletion request (described above), please contact us by any of the following means:

To prevent your Personal Information from being sold, you can contact us via the link below as well as toll-free phone number and contact form to allow consumers to submit their opt-out requests.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your deletion request.
Upon receiving an access or deletion request from you, we will first verify your identity by requiring you to submit your name and e-mail address, and by matching the information you provide with what we already have on file.

If you use an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent signed permission to do so, (2) verify your own identity directly with us (as described above), and (3) directly confirm with us that you provided the authorized agent permission to submit the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

3. Changes to this CCPA Addendum

We may change this CCPA Addendum from time to time. The “Date last updated” at the top of this page states when this CCPA Addendum was last updated; any changes will become effective upon us posting the revised California Addendum.

We will post a prominent notice on the site to notify you of any significant changes to this CCPA Addendum and indicate the date it was most recently updated.

4. Contact Us

If you have any questions or concerns regarding this CCPA Addendum or our privacy practices, please contact us at our office address or contact form described in “2. Information about Us” in the Policy.