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Privacy Notice for California Residents

Last Updated: October 8, 2020

If you are a California resident, please read the following Privacy Notice for California Residents (“Policy”).

This Policy describes how information obtained from California consumers, including visitors to the Self Esteem Brands, LLC’s (“Self Esteem Brands”, “we”,  “us” or “our”) website found at https://demo.sebrands.com, or any related site hosted by Self Esteem Brands (“Website”) is collected, used, and disclosed.  This Policy also explains how you can make requests to know about your personal information and delete your personal information.  Please note that this Policy applies to information collected by us, where applicable.

Terms included in this Policy, including but not limited to, personal information and service provider, carry the same meaning in this Policy as they do in the California Consumer Privacy Act of 2018, California Civil Code sections 1798.100 et seq. (“CCPA”).  Additionally, and to protect your privacy, we do not sell, share, or rent your Personal Information in any way, as outlined in Section 7 below.   If our business practices should change in the future, we will inform you of this change before selling your Personal Information and provide you with instructions on how you can opt-in.

For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:

California’s Shine the Light Law

California Consumer Privacy Act

  1. California Residents’ Rights Under the CCPA
  2. Categories of California Consumers’ Personal Information Collected or Disclosed
  3. Methods for Submitting CCPA Requests to Us
  4. Verification Process
  5. Authorized Agents
  6. Response Timing and Format
  7. We Do Not Sell Your Personal Information
  8. Financial Incentive Offers
  9. Metrics Regarding CCPA Requests and Responses During the Previous Calendar Year
  10. The Rights of California Consumers Who are Less than 16 Years of Age
  11. Contact Us for More Information

CALIFORNIA’S SHINE THE LIGHT LAW

Subject to certain limits under California Civil Code section 1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal data that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make one request per calendar year.

To make this request, you may contact us at the mail or email address listed in the “Contact Us for More Information” section below. In your request, please state that you are a California resident and provide a current California address for our response. Please allow up to thirty (30) days for a response. We reserve our right not to respond to such requests submitted to addresses other than those specified in the “Contact Us for More Information” section below.

CALIFORNIA’S CONSUMER PRIVACY ACT

1. California Residents’ Rights Under the California Consumer Privacy Act

If you are a California resident, you have certain rights regarding information that is treated as Personal Information under the CCPA.

The right to know what categories of Personal Information are being collected or disclosed and the categories of sources of that Personal Information

You have the right to know what categories of Personal Information we collect, sell, or disclose about you, as well as the categories of third parties who received your Personal Information and the categories of sources of that Personal Information.  These categories are described in the “Categories of California Consumers’ Personal Information Collected or Disclosed” section below.  We are also required to provide to you, before or at the point of collection, with a general notice about the categories of Personal Information collected by us and how we intend to use the collected Personal Information.

The right to access collected Personal Information

You have the right to request that we provide a copy of your Personal Information that we collected or disclosed in the preceding twelve (12) months. Only you, or someone you legally authorize to act on your behalf, may make a request related to your Personal Information. You may submit a maximum of two requests in a 12-month period.

You must provide sufficient information to enable us to reasonably verify your identity or that of your authorized agent. We will only use the Personal Information provided in your request to verify your identity or that of your authorized agent.  Please note that we cannot provide any Personal Information in response to a request if we cannot verify your or your authorized agent’s identity, or your authorized agent’s authority to make the request on your behalf, and/or if we cannot confirm that the collected Personal Information relates to you.

You are not required to create an account with us before submitting a verifiable request. Please submit your request using the online Data Privacy Request form found at https://demo.sebrands.com/dataprivacyrequest, or by calling our Data Privacy Request toll-free number at (888) 503-0531.

After receiving and verifying your request, we will provide the following information (depending on your request):

  • The categories of Personal Information collected about you in the preceding twelve (12) months.
  • The sources of that Personal Information by category.
  • The business or commercial purpose(s) for collecting that Personal Information.
  • The categories of third parties with whom we shared that Personal Information.
  • The specific pieces of Personal Information collected about you.

If we disclosed your Personal Information for a business purpose, we will provide:

  • the categories of Personal Information disclosed for a business purpose in the previous twelve (12) months and the categories of third parties to whom the Personal Information was disclosed.

See the “Methods for Submitting CCPA Requests to Us” section below for information on how you can exercise your right to access collected Personal Information. For more information, see also the “Response Timing and Format” section below.

The right to request deletion of Personal Information

With certain exceptions, you have the right to request that we and our service providers delete Personal Information we or our service provider collected or maintained. Once we receive and verify your request, we will delete and instruct any applicable service providers to delete your Personal Information from our records, unless an exception applies.

We and our service providers may deny a verified deletion request if we must maintain your Personal Information to:

  • Complete the transaction or provide a good or service requested by you for which we collected the Personal Information, or otherwise perform a contract between us.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality of our systems.
  • Exercise a legal right provided for by law, including exercising or ensuring free speech rights.
  • Comply with the California Electronic Communications Privacy Act (California Penal Code sections 1546 to 1546.4).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if:
    • the research adheres to all other applicable ethics and privacy laws;
    • deleting the Personal Information is likely to make the research impossible or seriously impair it; and
    • you provided informed consent during the initial data collection.
  • Enable our internal use in a manner that you would reasonably expect based on your relationship with us.
  • Comply with our legal obligations.
  • Otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.

See the “Methods for Submitting CCPA Requests to Us” section below for information on how you can exercise your right to delete collected Personal Information.

The right to be free from discrimination

You have the right to equal service, and we will not discriminate against you if you exercise your rights under the CCPA. However, under certain circumstances, we may offer you special discounts or other incentives for the right to continue to collect or use your Personal Information.  In that event, we will notify you of the relevant program’s material terms and obtain your voluntary opt-in consent to the program.

2. Categories of California Consumers’ Personal Information Collected or Disclosed

We may collect categories of Personal Information about California consumers, their household, and/or their devices from both online and offline (such as hard-copy forms) sources.  We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing advance notice.

In particular, the following types of Personal Information we may have collected and reason for collection in the last twelve (12) months includes but is not limited to:

  • Information provided by you when you contact us via our online forms (e.g., “Contact Us”, “Learn More”) on our Site;
  • Information provided by you when you participate in a survey or communication to you regarding your use of the Site;
  • Information provided by you to participate in advertising contests or sweepstakes;
  • If you are a prospective employee, we (or our third party partner) may collect information when you submit your online application;
  • If you are a prospective franchisee, we may collect detailed information such as your first name, last name, email address, phone number, address, and general financial information such as liquidity and assets, to evaluate your qualifications for afranchise;
  • If we offer alternative sign ins, we may collect certain sign on information you have provided to third parties, such as Facebook or Twitter, when you sign on to use our Website or Apps through these third parties;
  • Computer data or files, often called “cookies,” which may be sent by your web browser and stored on an individual computer to allow our server to “recognize” you through the navigation of the Website and for us to credit your account for various online transactions;
  • Computer data files, often called “web beacons” that are collected from emails or links on third-party sites that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party sites; and
  • Your IP address to measure our website traffic and to help provide a more personalized experience.

Information obtained from your Social Media Accounts:

  • You may choose to log into the Website or through our Apps via certain social media networking services, such as Facebook and Twitter (“Social Media Accounts”). By integrating these Social Media Accounts into your account, we are able to offer you more personalized services, but may also collect certain personal information provided in your Social Media Accounts, such as your profile information, email address, profile picture and friend list.  If you do not want us to have access to this information, do not utilize the Social Media Account sign-in feature.

We may have shared or disclosed for a business purpose the following Personal Information with the following recipients:

  • Personal Identifiers. Recipients of this information may include affiliates and subsidiaries, website development and (cloud) hosting providers, email platform provider, marketing analytics companies and business partners.

3. Methods for Submitting CCPA Requests to Us

You have the right to submit a verifiable request to us using the following methods:

  • Online Request Form. You may submit a data privacy request by completing the online Data Privacy Request form located here: https://sebrands.com/dataprivacyrequest.
  • Toll-Free Telephone Call. You may submit requests by calling our toll-free Data Privacy Request number at 1-(888) 503-0531. A member of our team will process your request as applicable.
  • Club Locations. If you are at any of our clubs in California, you will be asked to submit the data privacy request using either of the two options referenced above (online form or toll-free number).

4. Verification Process

Once we receive a request to know or to delete, we must verify your identity before we can respond.  You may be required to provide the following information for verification purposes and efficiency when applicable:

  • Your first and last name
  • Your e-mail address
  • Your telephone number

If you submit either a request to know specific pieces of Personal Information collected, or a request to delete sensitive, irreplaceable, or otherwise valuable Personal Information, you (or your authorized agent, if applicable) will be required to provide a signed declaration affirming your identity (or your authorized agent’s identity, if applicable).

5. Authorized Agents

An authorized agent is either a natural person or a business entity registered with the California Secretary of State that a consumer has authorized to act on his or her behalf.  You may use an authorized agent to submit a request to know or request to delete. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the authorized agent provide either (1) a power of attorney or (2) proof of your written permission. In addition to proof of your written permission, we may require you to verify your own identity and directly confirm that you provided the agent permission to submit the request.

6. Response Timing and Format

Acknowledgement of receipt of request

We will confirm receipt of a request from you within ten (10) days. This confirmation will provide information about how we will process the request, including a description of our verification process and an approximation of when we will send you a substantive response.

Substantive Response

We will respond to a verifiable request from you within forty-five (45) days.  If we cannot respond in that time, we will notify you in writing that we need an additional forty-five (45) days and explain the reason for the needed additional time.  If you have an account with us, we will respond to that account. If you do not have an account with us, we will deliver the written response by mail or e-mail, at your option. Any disclosures we provide will cover only the 12-month period preceding our receipt of your verifiable request. If we cannot comply with your request, we will explain why. If you have requested to know specific Personal Information we collected, we will provide that information to you. 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 the request.

7. We Do Not Sell Your Personal Information

To protect your privacy, we do not sell, share, or rent your Personal Information as such terms are defined under the CCPA.  In the event that our business practices should change in the future, we will inform you of this change before selling your Personal Information and provide instructions on how you can opt-in.

8. Financial Incentive Offers

At this time, we do not offer any financial incentives or price or service differences that relate to our collection, retention, or use of your Personal Information. However, if this changes, we will provide a written description of the material terms of the financial incentive or price or service difference to you in a written Notice of Financial Incentive and you will only be enrolled as a participant if you affirmatively opt-in to the program. You may revoke your opt-in consent at any time. The Notice of Financial Incentive will explain the processes for opting-in to participate and revoking your consent (opting-out).

9. Metrics Regarding CCPA Requests and Responses During the Previous Calendar Year

At the end of each calendar year, starting in 2020, we will report as applicable regarding the number of requests to know or requests to delete that we received, complied with in whole or in part, or denied, and the median length of our response time.

10. The Rights of California Consumers Who are Less than 16 Years of Age

Under California law, consumers who are less than 16 years of age must provide affirmative authorization, or a parent or guardian of a consumer less than 13 must provide affirmative authorization, before a business may sell their Personal information. This is referred to as the “right to opt-in.” We do not have actual knowledge that we sell the Personal Information of California consumers who are less than 16 years of age.

For avoidance of doubt, our Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information on the Website. If you are under 16, do not use this Website or provide any information on this Website.  If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@sebrands.com.

11. Contact Us for More Information

California consumers who have questions or concerns about our privacy policies and practices may contact a trained representative through one of the following methods:

Toll-free call: (888) 503-0531

Email: privacy@sebrandss.com

Mail:

Self Esteem Brands, LLC
Attention: Data Protection Officer
111 Weir Drive
Woodbury, Minnesota 55125
U.S.A.

When contacting us, please include in the communication or have available the information listed under the “Verification Process” section above. If using an authorized agent, please include in the communication or have available proof of authorization.