The California Consumer Privacy Act

Notice to California Residents

Last Update:  December 2, 2020

This Notice to California Residents (“CCPA Notice”), provided by ADC Solutions USA, LLC., dba: Horizon Brands, LLC., and its subsidiaries and affiliate companies, including, but not limited to, ADC Solutions Hardware, LLC and ADC Solutions Auto, LLC (collectively, “Horizon Brands,” “we”, “us,” “our”)  pursuant to the California Consumer Privacy Act (“CCPA”), applies to natural persons who reside in the State of California (“consumers” or “you”), that access and use our various Horizon Brands Digital Properties, apply for a job with us, or otherwise engage or interact with us. Any terms used herein but not defined shall have the meaning assigned in our Privacy Policy, or the CCPA, as applicable. 

In the event of any conflict or inconsistency between this CCPA Notice and our Privacy Policy, this CCPA Notice shall control only with respect to the Personal Information (as defined in CCPA) of consumers, their households or devices. If you are located outside of the State of California this CCPA Notice does not apply to you and you should refer to our Privacy Policy.

Information We Collect

Categories of Personal Information. The Sill has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the date of the Last Update of this CCPA Notice (“Last Update”).  Personal Information does not include (i) publicly available information from government records; (ii) deidentified or aggregated Personal Information; or (iii) information excluded from the CCPA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996,  the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act.

    • Identifiers, such as your name, driver’s license number, passport number, tax identification number, mailing address, email address, phone number, and online identifiers.
    • Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)), such as your name, driver’s license number, passport number, tax identification number, mailing address, phone number, education, employment, employment history.
    • Protected classification characteristics under California or federal law, such as your age and gender.
    • Commercial Information. When you make a purchase or return, we collect information about the transaction. This may include product details, purchase price, date, receipts, location, and vehicle information (typically; brand, model, and year), if related to the product being purchased.
    • Internet or network activity information, such as computer's operating system, Internet Protocol (IP) address, unique device identifier, internet service provider, browser type/version, operating system and language, browsing history, interactions with our Digital Properties, and referral URL (i.e., the external source by which you arrived at our Digital Properties, or the pages you’ve clicked on while on our Digital Properties).
    • Geolocation Data, such as device location. We may collect or infer information about your general location when you access or use the Services, or turn on Bluetooth, Wi-Fi or other geolocation functionality on your device.
    • Audio or similar information.We record and store telephone calls and chat transcripts for a period of time when you interact with our customer or technical support personnel.
    • Professional or employment-related information. Current or past job history or performance evaluations
    • Non-public education information. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
    • Inferences. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes

Categories of Sources. We collect Personal Information from various sources, which vary depending on the context in which we process that Personal Information.

    • Directly from you – We collect information directly from you. For example, we collect information when you interact with our websites, place an order, download, or request our mobile applications, sign up for our mailing list, or when you apply for a job. We collect information when you sign up to receive news, notifications, or other communications from us. We also collect information when you request customer support; engage with us on social media; fill out a form; or participate in a survey or promotion
    • Indirectly from you – We may also collect information about or generated by any device you have used to access internal IT services, applications, and networks. Example: through our server logs and the placement of cookies.
    • From business partners. We collect information from business partners. For example Costco, Amazon, Autozone.
    • From Service Providers (defined below).

Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each, a “Business Purpose”): (i) for the purposes set forth in the How We Use and Share the Information section of our Privacy Policy and (ii) as described to you when collecting your Personal Information or as otherwise permissible under the CCPA.

Categories of Third Party Recipients. We may share your Personal Information with the following Categories of Third Party Recipients for Business Purposes:

    • “Services Providers,” which include: cloud hosting providers, technical assistance and security, database management/back-up services, analytics, digital marketing (e.g., marketing automation), customer relationship management, customer service, providers of administrative services, payment processors, suppliers, distribution channels
Disclosures of Personal Information for a Business Purpose. In the twelve (12) months preceding the Last Update, we may have disclosed (as the term is broadly defined under the CCPA and interpreting regulations) the Categories of Personal Information for a Business Purpose to the Categories of Third Parties set forth in Table I. In the twelve (12) months preceding the Last Update, we have not sold your Personal Information.

Table I

Categories of Personal Information Collected

Categories of Third Parties with Whom We Share this Personal Information for a Business Purpose

Identifiers

Service Providers

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e))

Service Providers

Protected classification characteristics under California or federal law

Service Providers

Commercial Information

Service Providers

Internet or other similar network activity

Service Providers

Geolocation data

Service Providers

Professional or employment-related information.

Service Providers

Non-public education information

Service Providers

Inferences

Service Providers


Your Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.

Right to Know About Personal Information. You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):

    • The categories of Personal Information we collected about you in the (12) months since the Last Update;
    • Specific pieces of Personal Information we collected about you in the twelve (12) months since the Last Update (also known as a data portability request);
    • The categories of sources from which we collected such Personal Information;
    • The Business Purpose for collecting that Personal Information about you; and
    • The categories of Personal Information we disclosed or sold for a Business Purpose and the categories of recipients to whom the Personal Information was disclosed or sold.

Right to Request Deletion. You have the right to request that we delete the Personal Information we have collected from you or maintain about you, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Right to Opt-Out of the Sale of Personal Information. In the twelve (12) months preceding the Last Update, we have not sold your Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”) should we begin to do so. We will not knowingly sell the Personal Information of children under the age of 16, unless we receive affirmative authorization (the “right to opt-in”) from either (i) the consumer who is between 13 and 16 years of age, or (ii) the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by clicking Do Not Sell My Personal Information. Once you make an opt-out request, we will not ask you to reauthorize Personal Information sales for at least twelve (12) months. However, you may change your mind and opt back in to Personal Information sales at any time by sending us an email making this request to privacy@horizon-brands.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CCPA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.

Notice on Financial Incentives. We may offer you certain financial incentives permitted under the CCPA for the collection, sale or deletion of your Personal Information that may result in different prices, rates, or quality levels, provided that: (i) the financial incentive is reasonably related to the value of your Personal Information and (ii) we provide you written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Details about specific financial incentives such as materials terms, the Categories of Personal Information implicated, how you may opt-in to the incentive program, how you may exercise the right to withdraw, and a good faith estimate of the value of the data shall be disclosed to you at or before you opt-in to such financial incentives and provide Personal Information. 

Right to Designate an Authorized Agent. If you submit a request to know, delete or opt-out of the sale of your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

Submitting a Request to Know or Delete under the CCPA
. To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by either: (a) visiting [WEBFORM] or (b) submitting your request by email to privacy@horizon-brands.com. You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) 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 Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you.

Verification Process and Required Information. We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your email address, full name, billing address (with zip code) and phone number, and some access requests may require (if you have made a purchase with us) that you identify some items ordered. If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

There may be information that is designated as Personal Information under the CCPA but this information, on its own, does not allow us to identify you in our systems—for example, search or browsing history. If this information is the only information we have collected on you, we will notify you that you are unidentifiable to us and we will be unable to comply with your request.

Response Timing and Format. We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 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 readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights
Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
To make such a request, please send an email to privacy@horizon-brands.com.

Changes to Our CCPA Notice
This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice.  We may change this CCPA Notice from time to time with or without notice to you. By visiting or accessing the Website, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect.  Please refer back to this CCPA Notice on a regular basis.

Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

E-mail:  privacy@horizon-brands.com

Postal address:
ADC Solutions USA, LLC.
2975 Red Hill Ave. Suite 100
Costa Mesa California 92626 US  

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