PRIVACY
CPM California Supplemental Privacy Policy
Last Revised: June 28, 2023
This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies only to information collected about individuals and businesses residing in California (“Consumer(s),” “you,” “your”) and supplements the information contained in our Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any and all regulations arising therefrom.
This Supplemental Policy describes CPM’s (“CPM,” “we,” “us,” or “our”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests.
If you are unable to review or access this Supplemental Policy due to a disability, you may contact CPM at [email protected] to access this Supplemental Policy in an alternative format.
Definitions Specific to this Policy
- “Consumer” means a natural person who resides in California, Colorado, Virginia, Utah and Connecticut and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
- “Personal Information” 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.
- “Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 5) Union membership; 6) Contents of email or text messages, unless we are the intended recipient; 7) Genetic data; 8) Biometric information used to uniquely identify the Consumer, and 9) Health, sex life, or sexual orientation.
- “Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA.
- “Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA.
Other terms used in this Supplemental Policy may be defined under the CCPA and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information we may collect examples of Personal Information in each category; types of sources from which each category of Personal Information is collected; the business purposes for which each category of Personal Information is collected; and the types of Vendors or Third parties with whom that category of Personal Information is shared. As this chart shows, we may share or sell Personal Information to Third Parties or disclose certain Personal Information to Vendors for business purposes.
| Category of Personal Information | Examples | Sources from Which This Personal Information is Collected | Business Purposes for Collection | Types of Vendors or Third Parties with Whom This Personal Information is Shared, Sold or Disclosed |
|---|---|---|---|---|
| Unique Identifiers | Real name, signature, alias, address, unique personal identifier, online identifier, IP address, email address, account name | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Managing your preferences -To help you finalize your purchases if your cart is abandoned -Customer service communications -Other Promotions | Disclosed: -Service providers -Contractors Shared or Sold: -Business partners-Marketing providers -Analytics providers -Social media |
| Contact and Financial Information | Name, address, telephone, email, credit card number, debit card number, or any other financial information | -Directly from you via our website -Claims management providers | -Complete transactions -Other services and discounts -Process claims -Prevent fraud | Disclosed: -Service providers -Contractors Shared or Sold: -None |
| Commercial Information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions | Disclosed: -Service providers -Contractors Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media |
| Internet or Other Electronic Activity | Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement | -Directly from you via our website -Direct communication with you -Social media interaction with you -Marketing agencies | -Provide you with goods and services -Invite participation in surveys and feedback -Customer service communications -Improve promotions | Disclosed: -Service providers -Contractors Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media |
| Geolocation Data | Device location | -From your digital device -Direct communication with you -Social media interaction with you | -Provide you with goods and services -Customer service communications -Improve promotions | Disclosed: -Service providers Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media |
Sensitive Personal Information We Collect and Disclose
| Category of Sensitive Personal Information | Sources From Which This Sensitive Personal Information is Collected | Business Purposes for Collection | Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed |
|---|---|---|---|
| Account log-in, financial account, debit card number, plus an access code | -Directly from you you via our website | -Complete transactions -Offer services and discounts -Prevent fraud | Disclosed: -Service Providers -Contractors Shared or Sold: -None |
| Precise Geolocation | -From your digital device -Direct communication with you -Social media interaction with you | -Provide you with goods and services -Customer service communications -Improve promotions | Disclosed: -Service providers Shared or Sold: -Business partners -Marketing providers -Analytics providers -Social media |
We will not collect a category of Personal Information not listed above or use that Personal Information for a business purpose not listed above, without first providing you with notice.
Retention of Data
We retain Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed above.
Your Rights to Your Personal Information
You have the right to request certain information regarding the Personal Information we have collected about you. You may make such a request up to twice in a 12- month span. Please note that there are circumstances in which we may not be able to comply with your request, including when we cannot verify your request or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request, if this is the case.
Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:
- The categories of Personal Information to be collected;
- The purposes for which the categories of Personal Information are collected or used;
- Whether or not that Personal Information is sold or shared with Third Parties or disclosed to Vendors;
- If the business Collects Sensitive Personal Information, the categories of Sensitive Personal Information to be Collected, the purposes for which it is Collected or used, and whether that information is Sold or Shared; and
- The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by contacting us as at the contact information provided below.
Right Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:
- Specific pieces and categories of Personal Information we collected about you;
- The categories of sources from which Personal Information was collected;
- The purposes for which Personal Information was collected, shared, sold, or processed;
- The categories of Personal Information we shared, sold or disclosed; and
- The categories of Vendors or Third Parties with whom we shared, sold or disclosed Personal Information.
Right to Delete. You have the right to request that we delete certain Personal Information that we have collected.
Right to Correct. You have a right to request that we correct any inaccurate Personal Information we may retain about you.
Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the Sale and Sharing of your Personal Information with Third Parties, and the right to opt out of the processing of Personal Information for targeted advertising purposes, as defined in the CCPA.
We do not Sell or Share Personal Information or process Personal Information for targeted advertising purposes. We also do not knowingly Sell or Share Personal Information of Consumers under 16 years of age.
Right to Limit the Use of Your Sensitive Personal Information. You have the right to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average Consumer or for specific business purposes defined by applicable law.
We do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA.
Right to Non-discrimination. You have a right to exercise the above rights and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted by the CCPA.
Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click [HERE] or call us at 1-800-366-2563. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at [email protected].
You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.
Right to Appeal. You have the right to appeal our decisions about your data subject requests. If you choose to appeal a decision, your request will move from Sales to our Legal Department for review. If you would like to appeal a decision regarding your data request, please click [HERE] or call 1-800-366-2563. Please state that your request is an “Appeal,” and describe the date and nature of your original request.
Verification Process
When you submit a request to exercise your Data Subject Rights, we may ask you to provide information that will enable us to verify your identity.
If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:
- Verify your identity with us directly.
- Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.
We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof.
Personal Information of Minors
We are proud of our online information and we strive to ensure we don’t offend people of any age. However, our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years except as required pursuant to applicable law. If you believe that a child has submitted personal information to us, please contact us at [email protected] and we will delete the information.
Additional California Privacy Rights
Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”
Financial Incentives for California Consumers. Under California law, we may provide financial incentives to California consumers who allow us to collect, retain, sell, or share their Personal Information. These incentives may include a lower price for goods or services.
Changes to Our Supplemental Policy
CPM reserves the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post an updated policy on our website with the effective date.
Additional Information
If you would like additional information regarding our Supplemental Policy, please contact us at [email protected], 1-800-366-2563, or
CPM Holdings, Inc.
9879 Naples St. NE
Blaine, MN 55449
