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Privacy Notice for California Residents

Effective Date: January 1, 2019

Last Updated: December 31, 2019

 

Overview

This Privacy Notice for California Residents supplements the information contained in Jenne, Inc.’s Privacy Policy and applies solely to all visitors, customers, applicants, and others who reside in the State of California ("Consumer(s)" or "You"). Jenne, Inc. (“Jenne”) has adopted this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA will have the same meaning when used in this Notice.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the information that we collect about you, how we use it, and any disclosures of your Personal Information by Jenne to third parties for the third parties’ direct marketing purposes.

We take great pride in the relationship of trust we have built with our customers over the years and are dedicated to treating your Personal Information with care and respect. Pursuant to California Civil Code Section 1798.83(c)(2), Jenne does not share Consumers’ Personal Information with other companies without providing you with notice and an opportunity to Opt-Out of such direct marketing uses. For more information about our privacy and data collection policies and your options for Opting Out, you may wish to review our Privacy Policy.

By using the Website and/or our Services, and providing us with Personal Information you agree to the practices described in this Privacy Notice and our Privacy Policy and to any updates to these policies posted here from time to time. To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the "Last Updated" date shown above.

Please Note: This Notice does not apply to employment-related Personal Information collected from California-based employees, who receive a separate notice from us.

 

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). Personal Information does not include:

  • Publicly available information including, but not limited to, government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of Personal Information from Consumers, as defined by the CCPA within the last twelve (12) months:

Category Examples Collected
A. 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. YES
B. 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, credit history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. (Please note that some Personal Information included in this category may overlap with other categories.) YES
C. 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). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). 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. YES
K. Inferences drawn from other Personal Information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

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

  • Directly from you. For example, from forms you complete or products and services you purchase or from trade shows or events where you have attended and provided your consent to collect your Personal Information.
  • Indirectly from you. For example, from observing your actions on our Website.
  • From Service Providers and Other Third Parties. For example, we may obtain Personal Information about you from third-party vendors that make products and services available through us, resellers that purchase products and services available from us and provide such products and services to you, and from third parties that have obtained or collected information about you and that have the right to provide that Personal Information to us. For example, we may contract with third parties that are in the business of providing information to businesses such as ours to verify certain information about you or obtain information.
  • From Publicly-Available Sources. For example, we may collect information from open government databases or other data sources in the public domain.
  • From Cameras and Telephones. For example, we may obtain your Personal Information from the CCTV cameras located in the offices and warehouses of the Jenne companies and from recordings of telephone calls.

Please note that Personal Information reflecting a written or verbal business to business communication (“B2B Personal Information”), is temporarily excluded from many of the requirements of the CCPA. (See below for more information.)

 

Use of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Website, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads via email (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • 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 about our customers and end users is among the assets transferred.
  • Any other purpose listed in our Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. 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.

We may share your Personal Information with the following categories of third parties:

  • Resellers, Vendors, and Service Providers.
  • Contractors, Affiliates and Other Business Partners.
  • Professional Advisors and other Agents and Representatives including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • We may share your Personal Information with any other person with your consent to the disclosure or to otherwise fulfill the purpose for which you provided it or any other purpose disclosed by us when you provided the Personal Information.

 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

Category K: Inferences drawn from other Personal Information.

 

Sales of Personal Information

In the preceding twelve (12) months, Jenne has not sold any Consumer Personal Information.

 

Your Rights and Choices

The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

1) Access to Specific Information and Data Portability Rights

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 (see Exercising Access, Data Portability, and Deletion), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we disclose your Personal Information for a business purpose, the Personal Information categories that each category of recipient obtained.

Please Note: We do not provide these access and data portability rights for B2B Personal Information.

 

2) Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

  1. Complete the 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Please Note: we do not provide these deletion rights for B2B Personal Information.

 

3) Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 1 (866) 451-7429
  • Emailing us at privacy@jenne.com Only you, or someone legally authorized to act on your behalf, 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 an authorized representative.
  • 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 relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to you by mail or electronically, at your option.

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 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.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

 

Changes to Our Privacy Notice

We reserve the right to update this Privacy Notice at any time. It is our policy to notify you of any changes that we make to this Privacy Notice or our Privacy Policy on these pages of our Website. If we decide to collect additional categories of Personal Information or use the Personal Information we have collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Notice, as well as the Privacy Policy.

The date this Privacy Notice was last updated is identified at the top of the page. If we make material changes to how we treat our California customers' Personal Information, we will notify you through a notice on our Website home page.

If we need or are required to contact you concerning any issue or event that involves this Privacy Notice, then we will do so using the email address, telephone number, or physical mailing address we have on file for you.

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Privacy Policy and this Privacy Notice to check for any changes.

Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

If you have any questions or comments about this notice, the ways in which Jenne collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Phone: 1 (866) 451-7429

Email: privacy@jenne.com

Postal Address:

Jenne, Inc.

Attn: Privacy Officer

33665 Chester Road

Avon, OH 44011

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