Addendum to GPPN: California Privacy Notice
This Addendum is adopted in compliance with California privacy law and supplements the CWT Global Privacy Policy and Notice solely for residents of the State of California ("consumers" or "you").
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 or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category |
Examples |
Identifiers |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
Protected classification characteristics under California or federal law |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
Commercial information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Internet or other similar network activity |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
Sensitive personal information |
Personal Information that reveals a consumer's social security, driver's license, state identification card, or passport number; a consumer's account log-In, financial account, debit card, or credit card number In combination with any required security or access code, password, or credentials allowing access to an account; a consumer's precise geo-location; a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer's mail, email and text messages, unless we are the intended recipient of the communication; a consumer's genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal Information collected and analyzed concerning a consumer's health; or personal Information collected and analyzed concerning a consumer's sex life or sexual orientation. |
We obtain the categories of personal information listed above from you and your devices and from third parties that interact with us in connection with the services we perform.
We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.
Use of personal information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To provide you with our products and services.
- To provide our products and services to corporate clients.
- To process payments.
- To operate websites and mobile applications.
- To operate and improve our business.
Sharing personal information
We may disclose your personal information to a third party for a business purpose. For example, we share your personal information with vendors who provide IT support and data hosting services. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we may have disclosed categories listed in the table above for a business purpose or at your direction with our affiliates, business partners, service providers, and other third parties. For more details about the third parties we share data with, see the HOW WE SHARE YOUR INFORMATION section in our Global Privacy Policy and Notice.
In the preceding twelve (12) months, we have not "sold" or "shared" any personal information as those terms are defined under applicable California laws.
Data retention
We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete personal information from our database at any time and without providing any reason.
Children
We do not knowingly collect personal information from children under 16 years old and we do not "sell" or "share," as those terms are defined under applicable California laws, the personal information of children under 16 years old. If a child under 16 years old has provided us with personal information, we will delete that personal information as soon as possible.
Your rights and choices
Subject to certain exceptions, as a California resident, you may have the right to:
- request, up to two times a year access to your personal information, including information about the categories of personal information we have collected, the categories of sources from which we have collected your personal information, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
- request deletion of your personal information;
- if we maintain any inaccurate information about you, request correction of inaccurate personal information;
- for sensitive personal information that we collect, request that we limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services and as otherwise authorized under applicable laws;
- request information about the personal information about you that we have disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
- request information about the personal information about you that we have "sold" or "shared" (as such terms is defined under applicable California laws) and the categories of third parties to whom the personal Information was sold or shared;
- request, under California Civil Code Section 1798.83 (“Shine the Light” law), information regarding the disclosure of personal information by certain business affiliates to third parties for the third parties’ direct marketing purposes.
- opt-out of the "sale" or "sharing" of your personal information (as such terms is defined under applicable California laws); and
- not be discriminated against for exercising your rights under applicable California laws.
Should you wish to exercise your other rights as detailed above with regard to your personal information, please complete our form. We may need to take steps, including requesting additional information from you, to verify your identity. For authorized agents submitting requests on behalf of California consumers, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization.
Notice of financial incentives
We may offer financial incentive programs to California residents. As a California resident, you must opt-in to participate in any financial incentive program we may offer after reviewing the terms of such program and the instructions for opting-in. You have the right to revoke your consent to participate in any financial incentive program we may offer at any time, and you may do so by contacting us as defined below.
Changes to this addendum
We reserve the right to amend this Addendum at any time to address future developments or changes in industry or legal trends. If we make material changes to this Addendum, we will post a notice on our website before the changes go into effect, and where appropriate, send a direct communication to you about the changes.
Contact us
If you have any questions, requests, or complaints about this Addendum, or to exercise your rights, please contact us at globalprivacy@mycwt.com.