CCPA POLICY

Last Updated: December 24, 2019

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in AARDVARK’s Privacy Policy and only applies solely to visitors, users, and others who reside in the State of California (“consumers” and “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”), commencing with California Civil Code §1798.100. 

 

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).  In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include: 

  • Publicly available information from government records. 

  • De-Identified or aggregated consumer information. 

  • Information excluded from the CCPA’s scope, such as: 

  1. 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; 

  2. 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. 

 

We obtain the categories of personal information listed above from the following sources: 

  • Directly from our consumers when they engage us. 

  • Indirectly from our consumers in the course of providing services to them. 

  • Directly and indirectly from activity on our website. For example, from submissions through our website services, account creation, or website usage details collected automatically. 

USE OF PERSONAL INFORMATION 

AARDVARK collects this information from consumers for one or more of the following business purposes: 

  • To comply with federal, state, and local laws. 

  • To respond to law enforcement requests as required by applicable law, court order, or governmental regulations. 

  • To perform the services requested of us by our consumers. 

  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you. 

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and AARDVARK, including for billing and collections. 

  • To improve our Website and present its contents to you. 

  • For research and analysis of our Website traffic. 

  • As necessary or appropriate to protect the rights, property, or safety of AARDVARK, our consumers, or others. 

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA. 

 

AARDVARK will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without first providing you notice. 

SHARING PERSONAL INFORMATION

AARDVARK may disclose your personal information to a third party for a business purpose (i.e. to a vendor/manufacturer that will be providing the product or service requested by the consumer). 

In the past twelve (12) months, AARDVARK has disclosed the following categories of personal information for a business purpose: 

  • Category A: Identifiers 

  • Category B: Personal information categories listed in the California Civil Code 

 

In the past twelve (12) months, AARDVARK has not sold any personal information. 

 

YOUR RIGHTS AND CHOICES

The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

Access to Specific Information and Data Portability Rights 

You have the right to request that AARDVARK 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, 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 purpose for collecting that personal information. 

  • The categories of third parties with whom we shared that personal information. 

  • The specific pieces of personal information we collected about you (also called a data portability request). 

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 

  1. Sales, identifying the personal information categories that each category of recipient purchased; and 

  2. Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

 

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, 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 AARDVARK or our service providers 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, 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). 

  6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. 

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 

  8. Comply with a legal obligation. 

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

 

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 AARDVARK by either: 

  • Calling us at 1-800-997-3773 

 

Only you or a person registered with the California Secretary of State that you authorize 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; and 

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

 

AARDVARK 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.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

 

Response Timing and Format 

AARDVARK will strive to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response 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 response we cannot comply with a request, if applicable. 

AARDVARK does 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 explain how we determined that decision and provide you with a cost estimate before completing your request. 

 

NON-DISCRIMINATION 

AARDVARK 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 POLICY 

We reserve the right to amend this CCPA policy or our Privacy Policy at our discretion and at any time.  When we make changes to either of these policies, we will make notice of this by the revision date of the policy on our Website(s).

CONTACT INFORMATION 

If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact AARDVARK at: 

AARDVARK 

1935 Puddingstone Drive 

Attn: Director of Policy & Regulatory Compliance 

La Verne, CA 91750 

1-800-997-3773 

privacy@aardvarktactical.com