California Closet Company, Inc.
CALIFORNIA PRIVACY NOTICE
Last Updated: January 1, 2023
This California Privacy Notice explains how California Closet Company, Inc. and its corporate affiliates (“we,” or “us,” or “our”) collect Personal Information of California residents based on your interactions with us, including on our websites, applications, forums, blogs (each a “Site” and collectively, the “Sites”), and other online or offline offerings and your other interactions with us (collectively, the “Services”).
We note that we are providing this Privacy Notice in accordance with the requirements of the California Consumer Privacy Act of 2018 (the “CCPA”), a law which requires business to make certain disclosures concerning how they collect, use, and share “Personal Information” (as defined below) and to grant California residents certain rights with respect to their Personal Information.
Personal Information We Collect and Have Collected in the Past 12 Months – Sources and Categories
In the 12 months preceding the date of this Notice, we collected your Personal Information when you visited our Sites, requested information about our Services, booked an appointment, registered for mailing lists, submitted comments or otherwise interacted with the Sites, emailed or called us, submitted a review or evaluation of our services, when you corresponded or interacted with us in your capacity as a representative of another entity that we receive or provide service to or from or otherwise interact with in a commercial capacity, from you in connection with a franchisee application, or when you voluntarily provided information to us through an email or phone call. We also collected your Personal Information from franchises and third-party data sources such as data aggregators and data brokers. We will continue to collect Personal Information from the same sources.
The categories of Personal Information we collected from these sources during the 12 months preceding the date of this Notice, and will continue to collect, includes the following:
- Personal identifiers: email address, address of the property we service, your home or billing address, telephone numbers, customer number, account password, estimated home value, and IP address or other unique identifier.
- Protected class characteristics: age, sex/gender, marital status
- Commercial and financial information: records of Services ordered or considered; other purchasing or consuming histories; and payment information. For franchise applicants, information about your assets, income, property and business ownership interests, and other financial information you provide to us.
- Internet or other electronic activity information: your device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Site and our advertisements.
- Geolocation information.
- Professional information: job title, information about your employer and employment and business ownership history for franchise applicants.
- Audio information: recordings of customer service calls for quality assurance purposes.
- Inferences drawn from the Personal Information identified above.
Purposes for Collection of Personal Information
We use your Personal Information to provide you with the information you request and products and Services that are ordered by you or on your behalf. We also use the information you provide us to contact you from time to time, to provide you with information about our business, customer support, advertisements and marketing promotions and offers about products or services we think may be of interest to you, including our products and Services and those of our affiliates.
For those who interact with us in a commercial capacity, we use your Personal Information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.
We also use Personal Information about your use of our Sites to monitor or improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:
|Categories of Consumers’ Personal Information||Categories of Third Parties With Which We Shared Personal Information for a Business Purpose|
|Personal identifiers: name, email address, address of the property for which service is requested, home or billing address, telephone numbers, customer number, account password, and IP address, mobile ad ID address, estimated home value, or other unique identifier.||Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, process franchisee applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and services and those of our affiliates, provide analytics information, provide legal and accounting services, and host conferencing services. Subcontractors that perform specialized components of the Services we offer. Franchises.|
|Commercial information: records of products or Services purchased, ordered, returned, or considered; other purchasing or consuming histories; payment information; information about franchise applicants’ assets, income, property and business ownership interests, and other financial information provided.||Service providers that manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products or Services and those of our affiliates, provide analytics information, and provide legal and accounting services. Franchises.|
|Internet or other electronic network activity information: device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements.||Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and services and those of our affiliates, and provide analytics information.|
|Geolocation information||Service providers that advertise and market our products and services and those of our affiliates, provide analytics information.|
|Audio information: recordings of customer service calls for quality assurance purposes.||Service providers that provide customer service (including through our call center). Franchises.|
Additional Information About How We May Disclose Personal Information
We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your Personal Information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.
Categories of Personal Information We Sold to Third Parties in the Preceding 12 Months
We also allow third parties to use Technologies on our Site for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our Site. Some of these third parties use the Technologies to collect information about how you interact with other websites and advertisements across the Internet in order to provide advertising that is tailored to your interests and which may appear on our Site or on other websites or platforms.
To the extent our use of any of these Technologies constitutes a “sale” of Personal Information under applicable laws, you can direct us not to “sell” your Personal Information in that regard by clicking here.
CCPA Rights of Individuals
Your Right To Request Access to Information We Collect and Share About You
You can request the following information from us, with respect to the Personal Information that we have collected about you in the 12 months prior to our receipt of your request:
- Specific pieces of Personal Information we have collected about you;
- Categories of Personal Information we have collected about you;
- Categories of sources from which such Personal Information was collected;
- Categories of Personal Information that the business sold or disclosed for a business purpose about the consumer;
- Categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling your Personal Information.
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon your request, we will delete the Personal Information we have collected from you that is covered by the CCPA, except for situations where specific information is necessary for us to: provide you with a product or Service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Your Right to Ask Us Not to Sell Personal Information We Have Collected About You
Under the CCPA’s broad definition of the term “sale,” we sell Personal Information by allowing third parties that facilitate digital advertising to place cookies and other trackers that collect information about your browsing and interactions with other websites and to use that information to deliver information to you about products and services in which you may be interested.
Exercising Your Rights and How We Will Respond
To exercise your rights to access or delete your Personal Information, or to ask a question, contact us at 1-833-973-0699, click here, or use the contact details set out at the end of this Privacy Notice. For access and deletion requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
You can also direct us not to sell your Personal Information [here]. We will act on your request within the timeframes set forth below. For requests to stop the sale of your Personal Information, we will comply no later than 15 business days after receipt of your request.
Verification of Identity – Access or Deletion Requests
We will ask you for two pieces of Personal Information (typically phone number and email address used when transacting with us) and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:
- Requests to Know or Delete Personal Information: If the agent submits requests to access, know or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
- Requests to Opt Out of Sale: If the agent submits a request to opt out of the sale of your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly. If you exercise your rights under this Privacy Notice, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Personal Information of Minors
Our products and Services are not directed to minors under the age of 13 and we do not knowingly collect or sell the Personal Information of minors under 16.
Do Not Track / Global Privacy Control
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals. We observe the Global Privacy Control signal.
California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. While we may use Personal Information to market third party products and services we believe may be of interest to our customers, we do not share Personal Information with third parties for their own marketing purposes.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented and maintained in accordance with applicable law and relevant standards. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Changes to This Notice
We will review and update this Notice as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Site or update the Privacy Notice modification date. In certain cases and if the changes are material, you will be notified via email or a notice on our Site.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 800‑225‑2567.
If there are any questions regarding this Privacy Notice or to request a copy of this Privacy Notice in another format you may contact us using the information below. firstname.lastname@example.org