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FOR CALIFORNIA RESIDENTS

CALIFORNIA PRIVACY RIGHTS

Last Modified: January 1, 2020

Solely for purposes of this portion of the Notice for California Residents, references to “we” and “us” shall be deemed references to SmartSource and references to “Services” shall be deemed references to services provided by SmartSource, including through (1) www.smartsource.com, (2) marketing experiences accessed via scannable quick response (QR) codes, near field communications or other methods, which may or may not relate to SmartSource, (3) surveys, product sampling and other offer distribution opportunities and (4) emails related to the above.

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA SHINE THE LIGHT LAW

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us as specified in the How to Contact Us section of the Notice.

For all such requests, please indicate "California Shine the Light" in the subject field of your request and include the name of the SmartSource Service with respect to which you are requesting the information. You must also include your full name and email address.

NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the Notice. Certain terms used below have the meanings given to them in the CCPA.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information:

CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU, WHY AND HOW

Summarized in the table below are the categories of personal information we may have collected about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.

Categories of information collected

Purposes of collection

Sources of personal information

Identifiers

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use
  • Affiliates and Partners

Commercial Data

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use
  • Affiliates and Partners

Internet Data

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use

Geo-location Data

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use

Inference Data

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use
  • Affiliates and Partners

Protected Data

  • Performing Services
  • Research and Development
  • Commercial Interests
  • You

Profile Data

  • Performing Services
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use
  • Affiliates and Partners

Associated Data

  • Performing Services
  • Auditing
  • Short-term Use
  • Data Security and Fraud Prevention
  • Repairs
  • Research and Development
  • Quality and Safety
  • Commercial Interests
  • You
  • Services Use
  • Affiliates and Partners

More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise set forth in the Information We Obtain and How We Use the Information We Obtain sections of our Notice.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

BUSINESS OR COMMERCIAL PURPOSES FOR WHICH WE COLLECTED OR DISCLOSED PERSONAL INFORMATION

CATEGORIES OF SOURCES FROM WHICH WE COLLECTED PERSONAL INFORMATION

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes. The chart below explains the categories of information that we may share with third parties and the categories of those parties.

Third Parties with which we share information and why

Categories of information shared

Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver products and services to you, and enhance our products, services, and your customer experience, consistent with our Notice. Those businesses may also use your information for their own purposes, including marketing purposes.

  • Any or all categories of information we collect may be shared with our affiliates

Third Party Partners for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. For example, if you print coupons, then we may share information with third parties for their marketing and other purposes.

  • Any or all categories of information we collect may be shared with our third party partners for marketing purposes

Third Parties for Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.

  • Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements

Third Parties for the Protection of our Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary to prevent physical harm or financial loss.

  • Identifiers
  • Commercial Data
  • Internet Data
  • Geo-location Data
  • Profile Data
  • Associated Data

Third Parties in Business Transfers. We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.

  • Any or all categories of information may be shared with third parties in a business transaction, depending on the specific transaction

Third-Party Online Advertisers and Ad Networks. As discussed in the Interest-Based Advertising of our Privacy Notice, the Services may rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads.

  • Any or all categories of information may be shared with third-party online advertisers and ad networks

Data Analytics Providers. We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.

  • Any or all categories of information may be shared with data analytics providers

Social Networks. As discussed in the Information We Share section of our Notice, we may share your information with social networking services for their commercial or marketing purposes.

  • Identifiers
  • Internet Data

Consumer Data Resellers. We may share information with consumer data resellers for marketing or commercial purposes

  • Any or all categories of information may be shared with consumer data resellers

CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES

California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure. You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:

The right to deletion. You may have the right to request that we delete the personal information we have collected from you.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

How to exercise your access and deletion rights.

California residents may exercise their California privacy rights by submitting a request through https://privacyportal-cdn.onetrust.com, by calling 888-222-8703 or by sending an email to californiaprivacy@smartsource.com

For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. For instance, you will need to provide: your full name and email address or such other information as is necessary to verify your identity. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, you will also need to provide: your full name and email address or such other information as is necessary to verify your identity or authenticate your request.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include, for example, allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior.

If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

AUTHORIZED AGENTS

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

HOW TO CONTACT US

If you are a California Consumer, to submit a request, please contact us at https://privacyportal-cdn.onetrust.com, by calling 888-222-8703 or by emailing californiaprivacy@smartsource.com. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

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