Privacy Notice for California Residents

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Effective Date: January 1, 2020

Last Updated on: December 18, 2019

Introduction

This CA Privacy Notice supplements the information contained Safelite’s Privacy Policy and describes our privacy practices with respect to individuals who reside in the State of California (“consumers” or “you”).

This CA Privacy Notice does not apply to information we collect when:

  • You are acting as a job applicant to Safelite;
  • You are acting in your capacity as a current or former employee, owner, director, officer, medical staff member, or contractor of Safelite;
  • You have been designated as an emergency contact for one of the persons listed above and your information has been collected for use solely within that context;
  • We need your personal information to administer benefits obtained through one of the persons listed above; or
  • Your personal information reflects a written or verbal business to business communication or transaction.

For information on our privacy practices as they relate to any of the above information collected from the above persons, contact us at: onlinehelp@safelite.com

We adopt this CA Privacy Policy to comply with the CCPA, as may be amended, replaced, or superseded as well as any implementing regulations. Any terms defined in the CCPA have the same meaning when used in this CA Privacy Policy.

Information we collect about California consumers

Safelite collects 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 or device (“personal information”). However, personal information does not include:

  • Publicly available information from government records.
  • Deidentified 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; and
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Specifically, we collect the following categories of personal information:

CategoryExamplesDo we collect this information?
 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 listed in 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, 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.


No
 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.

 

No
 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. 


No
 K.  Interferences drawn from other personal information

 

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


Yes

 

Why we collect your personal information

We may use or disclose the personal information in the above categories for 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 through our Website, third-party sites, and via email or text message (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.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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 consumers is among the assets transferred.

Notice of our collection, use, and disclosure of personal information in the last 12 months

In the last twelve (12) months, we have collected, used, and disclosed the following categories of personal information for a business purpose: 

1. Categories of information collected in the last 12 months

a. [Category A: Identifiers.]
b. [Category B: California Customer Records personal information categories.]
c. [Category F: Internet or other similar network activity.]
d. [Category G: Geolocation data.]
e. [Category H: Sensory data.]
f. [Category K: Inferences drawn from other personal information.]

2.  How we collected this information

We collect the above categories of your personal information from the following sources:

  • Directly from you. For example, from forms you complete or products and services you purchase, when you apply for a job for us, when you provide us services, as part of your employment for us.
  • Indirectly from you. For example, from observing your actions on our Website.
  • From third parties.  This includes third party data brokers, web analytics tools.

3. Why we collected personal information

we have collected and shared personal information in the above categories for 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 through our Website, third-party sites, and via email or text message (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.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
  • 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 consumers is among the assets transferred.
  • We may use the following categories of information Identifiers, California Customer Records personal information categories, Internet or other similar network activity, Geolocation data, Inferences, Inferences drawn from other personal information  for the reasons listed in  “Why we collect personal information”.

4.  Who we have shared this information with for a business purpose

For each of the above categories, we share your personal information with the following categories of third parties:

  • Service providers
  • Data aggregators
  • Advertising platforms 

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.

A. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Introduction), 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

B. 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 Introduction), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  

We may deny a 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 or 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 et. seq.).
  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.

C. Exercising Access, Data Portability, and Deletion Rights

  • How to submit requests

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

Calling us at: 1-800-270-5679

Clicking here to submit request online.

  • Who may submit requests

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 designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

  • How often can you submit requests

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

  • How we verify and respond to requests

Your request must be verifiable. That means that you, or your authorized representative, must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person. We may verify your request:

  • Through our existing authentication practices for your password-protected account with us. Making a verifiable consumer request does not require you to create an account with us, if you do not make a request through an account with us. 

We require you to provide first name, last name, phone number and service address or invoice number to verify requests  Your verifiable consumer request must also 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.

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

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 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. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

Statistics

For the previous calendar year, we:

• received 0 number of requests to know

• complied with 0 number of requests to know

• denied 0 number of requests to know

• received 0 requests to delete

• complied with 0 requests to delete

• denied 0 requests to delete

• received 0 opt-out requests

• complied with 0 opt-out requests; and

• denied 0 opt-out requests.

Other California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to onlinehelp@safelite.com or write us at: Safelite Group, Inc. Attn. Customer Care, 7400 Safelite Way, Columbus, Ohio 43235.

Who to Contact for more information

For questions or concerns about our privacy policy and practices, you can contact us at the method set forth below.

Email: onlinehelp@safelite.com
Toll free number: +1 877-664-8931

Mailing Address:

Safelite Group, Inc.
Attn. Customer Care
7400 Safelite Way
Columbus, Ohio 43235

 

 

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