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California Privacy Policy

Effective Date: January 1, 2020

Last Amended: February 11, 2020

Introduction

Lippert Components, Inc., and its subsidiaries (including CURT Group, CURT, ARIES, LUVERNE, UWS and RETRAC) and affiliates (collectively “LCI®,” “we,” “our,” or “us”) are committed to protecting your privacy. LCI strives to protect the privacy of Personal Information in our custody, keeping with the access and privacy provisions of applicable legislation. We use this California Privacy Policy (“California Privacy Policy”) to supplement our Privacy Notice and this California Privacy Policy is parallel in scope to our Privacy Notice. We have adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to our Privacy Notice, including the following terms:

 “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.  Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

 “Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

The Personal Information We Collect and Disclose

The chart below shows the categories of Personal Information we may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, we sell certain Personal Information to third parties.

Category of Personal Information Examples Types of Sources from which this Category of Personal Information Is Collected Business Purposes for Collection Types of Third Parties with Whom this Category of Personal Information is Shared/Sold and/or Disclosed
Unique identifiers

Name, signature, address, telephone email, account name, online identifier, IP address

-Directly from you

-Devices you use

-Purchased businesses

-Social media platforms

-Analytics partners

-Provide information, products and services

-Security, credit or fraud prevention

-Provide customer service and assess satisfaction

-Personalize customer experience

-Improve marketing and customer communications

-Comply with legal obligations

Disclose:

-Hosting companies

-Financial institutions and payment processors

-Delivery or courier providers

-Original Equipment Manufacturers

-Courts or other entities per a legally-binding request

 

Shared/Sold:

-Online analytics providers

-Online advertisers

-Social media platforms
Financial information Credit card number, debit card number, or any other financial information

-Directly from you

-Purchased businesses

-Affiliates, counter parties, or other agents authorized to disclose information on behalf of a client

-Process payment transactions

-Comply with legal obligations

Disclose:

-Financial institutions and payment processors

-Courts or other entities per a legally-binding request
Purchase history Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

-Directly from you

-Purchased businesses

-Affiliates, or other agents authorized to disclose information on behalf of a client

-Complete transactions

-Customer communication related to goods and services

-Process claims

-Marketing communications

Disclose:

-Hosting companies

-Financial institutions and payment processors

-Delivery or courier providers

-Courts or other entities per a legally-binding request

 

Shared/Sold:

-Online analytics providers

-Online advertisers
Internet activity Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement

-Directly from you

-Devices you use

-Social media platforms

-Analytics partners

-Personalize customer experience

-Improve products and services

-Monitor and improve website functionality

-Protect against security threats and misuse of our website and web applications

Disclose:

-Hosting companies

 

Shared/Sold:

-Online analytics providers

-Online advertisers

-Social media platforms
Geolocation data Geolocation data

-Directly from you

-Devices you use

-Social media platforms

-Analytics partners

-Provide information, products and services

-Personalize customer experience

Disclose:

-Hosting companies

 

Shared/Sold:

-Online analytics providers

-Online advertisers

-Social media platforms

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Personal Information of Minors

We are proud of our online information and we strive to ensure we do not offend people of any age. However, our web pages are not intended for children or minors under the age of sixteen years. Accordingly, we do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to us, please contact us at [email protected] and we will delete the information.

Information Collection

You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months.  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 pursuant to the CCPA, 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.

  • If you would like to request (1) the categories of Personal Information collected about you; (2) the categories of Personal Information sold; (3) the categories of third parties to whom the information was sold; and (4) the categories of Personal Information that were disclosed for a business purpose, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.
  • If you would like to request the specific pieces of Personal Information we collected about you, you may submit a request via this form or call us at 1-888-996-2813. The link will provide you with instructions for submitting your CCPA request.

Non-Discrimination

We do not offer financial incentives to collect personal information and we will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy.  Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

Deletion of Your Personal Information

You have the right to request that we delete certain Personal Information that we have collected.  Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/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.

  • If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.

Right to Opt-Out

You have the right to request that we do not sell Personal Information that we have collected.  If you exercise that right, please note that pursuant to the CCPA we may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated.  If opting-in is required, we will provide you with the necessary instructions.

  • If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, you may submit a request via this form or call us at 1-888-996-2813. The form will provide you with instructions for submitting your CCPA request.
  • If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell your Personal Information.

You have the right to opt-in to the sale of your Personal Information after you have opted out.  If you would like to opt-in to the sale of your Personal Information, please email us at [email protected] or call us at 1-888-996-2813.

Verification Process

In order to protect your information, we will confirm a requestor’s identity before responding to any request. If we are unable to identify you based on the information you provide with your request as compared with our records based on your previous interaction with us, we will let you know and may ask additional questions.

We will only send CCPA verification questions from [email protected] Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our CCPA verification email address listed above, do not respond.

Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf.

Pursuant to the CCPA:

  • Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
  • You must provide the authorized agent written permission to exercise your rights under the CCPA 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, as permitted by the CCPA.
  • Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us.  This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.

Additional Information

If you would like additional information regarding our California Privacy Policy, please contact us at [email protected] or call us at 1-888-996-2813.

Additional California Privacy Rights

California Civil Code Section § 1798.83 permits users of our web site that 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.”

Changes to Our California Privacy Policy

We reserve the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.

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