California Privacy Notice

Date Last Updated: September 12, 2024

 

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California you have the following rights with respect to your personal information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information About You.

Personal information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education related information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of personal information we have collected about you; the categories of sources from which we collect personal information; our business or commercial purpose for collecting, disclosing, sharing or selling personal information; the categories of third parties to whom we disclose, share or sell personal information, if any; and the specific pieces of personal information we have collected about you. Personal information includes “sensitive” personal as described below.

1.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information About You.

“Sensitive” personal information as defined in the CCPA is personal information that reveals: (a) your social security, driver’s license, state identification card, or passport number; (b) your 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; (c) your precise geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (f) your genetic data. “Sensitive” personal information also includes biometric information that is processed for the purpose of identifying you, information that is collected and analyzed concerning your health; or your sex life or sexual orientation.

You have the right to know the categories of “sensitive” personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting, selling or sharing “sensitive” personal information, the categories of third parties with whom we sell or share “sensitive” personal information, if any, and the specific pieces of “sensitive” personal information we have collected about you.

1.3 Right to Delete Your Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers, contractors and third parties to delete your personal information from their records.

We are not required to, and reserve our right not to delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and (viii) comply with a legal obligation.

1.4 Right to Correct Inaccurate Personal Information.

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to correct any inaccurate personal information in our records, and to have us direct our service providers, contractors and third parties to correct any inaccurate personal information from their records.

If we cannot verify your identity pursuant to the CCPA and its regulations we may deny a request to correct. In such event, we shall inform you that your identity cannot be verified.

In determining the accuracy of the personal information that is the subject of your request to correct, we shall consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against you as an employee, applicant for employment or independent contractor.

1.6 Right to Opt-Out of the Sale of Personal Information

Under the CCPA, disclosure of your personal information to third parties in exchange for monetary or other consideration is considered to be a “Sale” of personal information. We do not provide sell your personal information.

1.7 Right to Limit the Use of “Sensitive” Personal Information

We use your “sensitive” personal information only to the extent that it is necessary to provide our goods and perform our services as reasonably expected by you. Since we already limit our use of your “sensitive” personal information to that which is necessary to provide our goods and perform our services as reasonably expected by you, we do not provide a “Limit the Use of My Sensitive Personal Information” link.

1.8 Right of Children to Opt-In to the Sale of Personal Information

We do not knowingly collect or sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please contact us at or email us at privacy@paparazziaccessories.com with the subject “Minor Opt-Out.”

 

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please submit your request to us at 1-855-967-2727 or at privacy@paparazziaccessories.com with the subject “CCPA Consumer Request.”

In order to verify your request, we will need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates. If feasible, we will match the identifying information provided by you with the personal information that we already maintain about you.

You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

 

3. RESPONSE TIMING AND FORMAT

If you send a verifiable consumer request, as set forth above, we will respond in accordance with state law. If we need additional time, we will inform you of the reason for the extension and the length of the extension. We will deliver our written response by e-mail.

Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. Alternatively, the response will explain the reasons we cannot comply with a request.

For data portability requests, we will provide your information in a form that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to a 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 and provide you with a cost estimate before completing your request.

 

4. OUR PERSONAL INFORMATION COLLECTION, USE AND DISCLOSURE PRACTICES

A description of the personal information that we collect online and off-line is provided in Section 2 of the main Policy. The purposes for which we collect and use personal information are described in Sections 2 and 4 of the main Policy. Sources from which we receive personal information are described in Section 3 of the main Policy. Our personal information disclosure practices are described in Sections 6 and 7 of the main Policy. Our personal information retention practices are described in Section 11 of the main Policy.

Communications: If you choose to contact us for any purpose, we will collect your name, contact details, and the date and time of your contact along with the content of your message. You may also choose to receive news, updates, or client alerts from us. When you sign up, we may collect your name, company, email address, and areas of interest.

Events: We collect personal information about you if you register for conference or other events we host or sponsor. This personal information may include your name, address, title, company, phone number, and email address, as well as specific information relevant to the event for which you register.

Other sources: We may receive personal information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or prevent or detect fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. Information we receive through such platforms is governed by the privacy settings, policies, and/or procedures of the platform, and we encourage you to review them.

Sources From Which We Collect Personal Information

In most cases, we collect personal information directly from consumers with which we interact. We also collect information from the following additional categories of sources:

• Independent Consultants.
• Data Analytics Providers.
• Email Marketing Providers.
• Payment Platforms.
• Service Providers.
• Social Networks.

Purposes For Which We Collect Personal Information

We collect personal information in order to support our independent consultants and provide them with everything they need to sell Paparazzi Accessories; and to allow customers to purchase Paparazzi Accessories directly through our independent consultants’ online storefronts. 

In addition to those purposes and the purposes described in our Privacy Policy, we also collect your personal information for the purposes of detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; debugging to identify and repair errors that impair existing intended functionality; short-term, transient use, where the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter your experience outside the current interaction; performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying client information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on our behalf; and undertaking activities to verify or maintain the quality or safety of services that are owned or controlled by us, and to improve, upgrade, or enhance those services.

Please note that we may process your personal information without your knowledge or consent, as required or permitted by law. We consider de-identification and aggregation of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

How We Share Personal Information

We generally disclose personal information as necessary to provide Paparazzi Accessories and support our Independent Consultants. In addition to the sharing described in our Privacy Policy, we also share personal information among our service providers and other third parties as described below:

Service Providers

We may from time to time use business partners, suppliers, and sub-contractors to assist us with the provision of services to you (for example, without limitation, website hosting, web analytics, maintenance services, database management, billing, payment processing, fraud protection, credit risk reduction, marketing, product research, or improvement of services). These entities have access to your personal information only to perform the respective tasks assigned to them on our behalf, and are obligated not to disclose or use it for any other purpose. For the purposes of this Notice, these are our “Service Providers.”

Third Parties

We may share personal information with the following categories of third parties: advertising networks, data analytics providers, government entities, operating systems and platforms, and social networks. For the purposes of this Notice, “Third Party” or “Third Parties” means third party as defined by the California Consumer Privacy Act, and includes parties that may sell, retain, use, or disclose personal information for certain purposes beyond the limited scope of our contract or direct business relationship with such entities.

Other Reasons for Which We Will Share Personal Information

We may cooperate with government and law enforcement officials as required by applicable law and/or in the course of legal proceedings. If you give us permission, or if we believe doing so is required or appropriate, we may disclose personal information to government or law enforcement officials or private parties in response to lawful requests, to comply with a legal obligation, to enforce or apply our terms and conditions, to protect our services, our rights, and/or the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Notice.

Categories of Personal Information Collected, Disclosed, and Sold.

Category of Personal Information Collected	Categories of Third Parties to Whom Sold in the Prior 12 Months	Categories of Third Parties to Whom Disclosed for a Business Purpose
Individual Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)	Data Analytics Providers*	Independent Consultants; Email Marketing Providers
Customer records that identify, relate to, describe, or are capable of being associated with, a particular individual (e.g. name, address, telephone number, education, employment history, credit card or debit card number)	Data Analytics Providers*	Independent Consultants; Email Marketing Providers; Payment Processors
Characteristics of protected classifications under California or Federal law (e.g., your gender or age)	None	None
Commercial information (e.g., information regarding products or services purchased, obtained, or considered)	None	Independent Consultants
Biometric information.	None	None
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our website)	Data Analytics Providers*	None
Geolocation data.	None	None
Audio, electronic, visual, thermal, olfactory, or similar information.	None	None
Professional or employment-related information.	None	None
Education information.	None	None
Inferences drawn from any of the information identified above.	None	None

 

*Our website uses Google Analytics.  We have configured Google Analytics such that we do not sell personal information, however this option was previously unavailable, and Google Analytics accordingly received web browsing information from our website in a manner that may have been considered a “sale” within the 12 months preceding this policy.

The above chart does not include information collected for employment related purposes or where you communicate or transact with us solely in the context of acting on behalf of a company, partnership, sole proprietorship, nonprofit, or government agency to engage in due diligence regarding, or providing or receiving a product or service to or from such entity.

The categories of information we collect for employment related purposes are: individual identifiers; customer records that identify, relate to, describe, or are capable of being associated with, a particular individual; characteristics of protected classifications under California or federal law; internet or other electronic network activity; professional or employment-related information; and education information.

 

5. OTHER CALIFORNIA PRIVACY RIGHTS

5.1 Shine the Light Request.

Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: privacy@paparazziaccessories.com with the subject “California Shine the Light Request” or 4771 S Desert Color PKWY, St George UT 84790 “attention: Legal”. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

5.2 Minor’s Right to Remove Posted Content.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacy@paparazziaccessories.comwith the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

 

6. CHANGES TO THIS PRIVACY NOTICE

We may update this Notice from time to time, in our sole discretion. When we do so, we will post the new Notice on our website. You should consult this Notice regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

 

7. ACCESSIBILITY NOTICE

For consumers who require this Notice in an alternative formation, it is provided on the Paparazzi website in a format that is compatible with text-to-speech technologies.  If you require additional formats or assistance, please contact us at the address, email, or toll-free phone number below.

 

8. CONTACT US

If you have questions regarding this Notice or our treatment of your personal information, you may contact us at the following:

Paparazzi Accessories

Attn: California Privacy

4771 S Desert Color PKWY

St George UT 84790

1-855-697-2727

privacy@paparazziaccessories.com 

 

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