California Privacy Notice
Last Updated: December 30, 2019
This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”).
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined the California Consumer Privacy Act (“CCPA”).
1. SCOPE
When we use the term “personal information” in these CA Disclosures, we mean 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.
For the purposes of these Disclosures, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- Information excluded from the CCPA’s scope, such as 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; or 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.
- Information relating to our employees, contractors and other personnel.
2. COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to our Privacy Policy.
In the last 12 months, we have collected the following categories of personal information:
| Category of Personal Information Collected | Collected | Categories of Sources |
|---|---|---|
| Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers. |  | • Directly from you • Our business partners and affiliates • Third parties you direct to share information with us • Social networks • Data sellers |
| California Customer Records (Cal. Civ. Code §1798.80(e)), such as birthdate, contact information and payment information. | | • Directly from you • Our business partners and affiliates • Third parties you direct to share information with us • Social networks • Data sellers |
| Commercial Information, such as shopping and purchase history. | | • Directly from you • Your browser or device |
| Internet/Network Information, such as device information, logs and analytics data. | | • Your browser or device |
| Geolocation Data, such as precise location information from your device or generated based on IP address. | | • Your browser or device |
| Sensory Information, such as recordings of phone calls with us, where permitted by law. | | • Directly from you |
| Profession/Employment Information, such as your company information and, for applicants, your employment history. | | • Directly from you • From our customers • For applicants, from third parties you direct to share information with us |
| Non-Public Education Information (20 U.S.C. §1232g, 34 C.F.R. Part 99), such as educational history, degree (for applicants) | | • Directly from you • Third parties you direct to share information from us |
| Other Personal Information, including information you post on our social media pages or otherwise provide to us | | • Directly from you • Third parties you direct to share information from us • Your browser or device |
| Inferences, such as predictions about your interests and preferences. | | • Your browser or device • Information generated or derived from your online browsing and usage activity |
3. DISCLOSURE OF PERSONAL INFORMATION
As described in the section called What do we use your information for in our Privacy Policy, we do not sell your information. We do share personal information with third parties for business purposes subject to your right to opt out of that (see The Right to Opt-Out of Personal Information below).
In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:
- All of the categories of personal information we collect, explained in the table above.
The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
- Our affiliate companies
- Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
- Businesses as needed to provide Services or to fulfil your request or transaction, including, for example, order fulfilment, payment processing, or delivery or shipping services;
- Ad networks and advertising partners to deliver advertising and personalized content to you on our Service, on other sites and services you may use, and across other devices you may use, as well as provide on behalf of advertising-related services such as reporting, attribution, analytics and market research;
- Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
- Social networks for advertising or personalization purposes, or to engage with you.
We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Policy.
Third-Party Tracking
We utilize third-party partners to track activity on our url and social media networks. These third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, social media platforms, or otherwise engage with us online. These third parties use your personal information to serve relevant ads on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
Please see our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those choices.
4. YOUR CALIFORNIA CONSUMER RIGHTS
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
| The Right to Know | • The specific pieces of personal information we have collected about you; • The categories of personal information we have collected about you; • The categories of sources of the personal information; • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and • The business or commercial purposes for collecting or selling the personal information. |
| The Right to Request Deletion | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| The Right to Opt Out of Personal Information Sales | You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. |
| The Right to Non-Discrimination | You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
| “Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). |
5. TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS
To exercise your California Consumer Rights, please submit a request by contacting CustomerService@cewmail.com.
We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Third Party Tracking and Online Advertising
We utilize third-party partners to collect certain personal information directly from your browser or device when you visit or interact with our websites and other online services for the purpose of serving relevant advertisements on our site, as well as on other websites or mobile applications, or personalize content or perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses will use personal information for their own purposes in accordance with their own privacy notice or privacy policy, which may include reselling this information to additional third parties. Please visit our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.
Minors Under Age 16
Our websites are not directed to minors. We do not sell the personal information of consumers we know to be less than 16 years of age.
California’s “Shine the Light” Law
California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please submit a California Consumer Rights Request to our customer service department at CustomerService@cewmail.com and provide your contact information to be added to our suppression list.
6. ADDITIONAL INFORMATION
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to CustomerService@cewmail.com.