CCPA POLICY-PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

 

The following applies only if you are a California resident. 

This Privacy Notice for California Residents supplements the information contained in Vedder Holster’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

If you are a California resident and would like a copy of this notice, please submit an email request to privacy@vedderholsters.com. The subject line must include the words “CALIFORNIA PRIVACY.” You must also include the statement “Your California Privacy Rights” in the body of the request, include the URL of the Site, as well as your full name, street address, city, state, and zip code.

 

Information We Collect 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). 

Within the last twelve (12) months, we have collected the following categories of Personal Information from California consumers. Some of the categories may overlap with each other:

Category

Examples

Identifiers

A real name, postal address, unique personal or online identifier, Internet Protocol (IP) address, email address, telephone number. 

Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e)) 

All of the Identifiers listed above, plus: credit card number (only when provided over the phone or via email or through our service providers or third-party payment processor).

Legally Protected Characteristics

Veteran or military status.

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

Internet or similar network activity

Browsing history, search history, information regarding a consumer's interaction with a website, mobile application, or online advertisement.

Geolocation data

Physical location or IP address.

Content you make public 

Information that you voluntarily upload to the Site for public display (“Public Information”), such as when you post a product review, comment on a good or service, or participate in a forum on the Site. Once you submit Public Information, neither you nor Company are able to control how it may be copied, shared, or used by third parties, even if you and/or Company later delete such Public Information. Accordingly, you should carefully consider what personal information you choose to include within your Public Information.

Inference Information 

Company may also create new information about you by drawing inferences from the information identified in the categories listed above, such as to create a profile about you reflecting your preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Personal Information does not include, for example, publicly available information that is lawfully made from federal, state, or local government records, deidentified or aggregated consumer information, or information regulated by the Fair Credit Reporting Act (FCRA).

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from our Users. For example, from information that you provide to us through our online forms, email, creating an account, or other means. 
  • Indirectly from activity on our Site. For example, from website usage details collected automatically.

 

Use of Personal Information

We may use or disclose Personal Information we collect for one or more of the following “Business Purposes” (i.e., uses reasonably necessary and proportionate to achieve an operational purpose):

  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information necessary to complete a purchase from the Site.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Vedder Holsters, including for billing and collections.
  • To improve our Site and present the contents to you.
  • For testing, research, analysis and product/service development.
  • As necessary or appropriate to protect the rights, property or safety of us, our users, or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We may also use or disclose the Personal Information we collect for the following “Commercial Purposes” (i.e., uses intended to advance Vedder Holster’s business interests, such as advertising or marketing a product or service): 

  • We may use your information to advertise to you after you use our Site or Services. 
  • We may create new information about you by drawing inferences from the information identified above, such as to create a profile about you reflecting your preferences and trends.
  • We may share your public content to advertise and market our Site and Services.

 

Sharing Personal Information

We may disclose your Personal Information to a third party for Business and/or Commercial Purposes. When we disclose Personal Information for Business Purposes, we require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for Business Purposes:

  • Identifiers.
  • Personal Information described in the California Customer Records statute.
  • Legally protected characteristics. 
  • Commercial information.
  • Internet activity.
  • Geolocation data.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information to third parties for Commercial Purposes:

  • Identifiers.
  • Personal Information described in the California Customer Records statute.
  • Commercial information.
  • Internet activity.
  • Geolocation data.

We disclose your Personal Information for Business Purposes to the following categories of third parties:

  • Our affiliated entities;
  • Our service providers, including our data analytics providers, payment providers, and email distribution services; and  
  • Third parties to whom you authorize us to disclose your Personal Information in connection with products or services we provide to you.

 

Sale of Personal Information

We do not sell consumers’ personal information and have not sold consumers’ personal information during the past twelve (12) months.

 

Your Rights and Choices 

The CCPA provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your rights under the CCPA and explains how you may exercise those rights.  

Right to Know About Personal Information Collected, Disclosed, or Sold

You have a right to request what Personal Information we collect, use, disclose, and sell. 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 as described below, we will disclose to you:

  • The categories of Personal Information we have collected about you;
  • The categories of sources for the Personal Information we have collected about you;
  • Our Business or Commercial Purposes for collecting or selling Personal Information;
  • The categories of third parties with whom we have shared Personal Information;
  • The specific pieces of Personal Information we have collected about you. In addition, if we sold or disclosed your Personal Information for Business Purposes, we will provide you with two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) disclosures for Business Purposes, identifying the Personal Information categories that each category of recipient obtained.  

 

California Shine the Light Disclosures

Under California’s “Shine the Light” law, California residents who provide Personal Information to Vedder Holsters may request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. 

 

Right to Access and Correction

You have the right to request access to or correction of the Personal Information we have collected about you. 

 

Right to Request Deletion of Personal Information

You have the right to request that we delete any or all of the Personal Information we have collected from you and retained, subject to certain exceptions. 

We may deny your deletion request if retaining the Personal Information is authorized by law, if it is necessary for us or our service providers to complete a 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, comply with a legal obligation, or make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Right to Non-Discrimination 

You have the right not to be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, if you exercise any of your California rights, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

How to Exercise Your Rights 

To exercise any of the rights described above, please submit a verifiable consumer request to us by emailing privacy@vedderholsters.com or calling 352-729-6749. Only you or your authorized agent may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

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 your 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 your Personal Information if we cannot verify your identity or authority to make the request. 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.

 

Response Timing and Format

We will confirm receipt of and respond to your verifiable consumer request, if and as required by law, within ten (10) business days and provide you with information about how we will process the request, describing our verification process and when you should expect a response. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding our receipt of your verifiable request. 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 useable and should allow you to transmit the information from one entity to another entity.

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.

 

Grievances and Complaints

You are entitled to file any grievances and/or complaints against Vedder Holsters with the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. You may submit written complaints to  400 R Street, Suite 1080, Sacramento, California 95814, you may contact by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

 

Contact for More Information

If you have any questions or concerns about our Privacy Policy or this Notice regarding your privacy or Personal Information, please contact us at privacy@vedderholsters.com.

 

Date last updated: November 9, 2020