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:

 

CATEGORY 

EXAMPLES 

COLLECTED 

A. Identifiers 

A real name, alias, postal address, unique personal identifier, IP address, email address, account name, social security number, driver’s license number, or other similar identifiers. 

YES 

B. Personal information categories listed in the California Civil 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. 

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). 

NO 

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 

Identifying physiological, biological or behavioral characteristics, including DNA, other identifying information such as fingerprints, handprints, faceprints, voiceprints, iris or retina scans, other physical patterns such as vein, keystroke, gait, and sleep, heath, or exercise data. 

NO 

F. Internet or other electronic network information 

Browsing history, search history, and information regarding an individual’s interaction with a website, application, or advertisement. 

YES 

G. Geolocation data 

Information that can be used to identify physical location. 

YES 

H. Audio, electronic, visual. thermal, olfactory, or other similar information 

Sensory data 

NO 

I. Professional or employment-related information 

Current or past job history or performance evaluations 

NO 

J. Non-public Education Information per the Family Educational Rights and Privacy Act in 20 U.S.C. §1232g 

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. 

NO 

K. Inferences drawn from other personal information. 

Profile reflecting an individual's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

NO 

 

Personal information does not include: 

  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: 

USE OF PERSONAL INFORMATION 

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

 

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: 

 

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: 

  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: 

 

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: 

 

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: 

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