CA Privacy Notice

CA Privacy Notice
Appendix A: Privacy Notice for California Residents

Last Updated: July 31, 2023

This Privacy Notice for California Residents (“California Privacy Notice”) supplements the information contained in Standso’s Privacy Notice, and applies to individuals who reside in the State of California (“consumers” or “you”) and whose Personal Information Standso has collected and who are not applicants to, or current or prospective employees of Standso.  If you are a job applicant or employee, your Personal Information is subject to Standso’s Employee Privacy Notice.  Any terms defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), have the same meaning when used in this notice. Any capitalized terms not defined in this Appendix or in the CPRA have the meaning provided in the Privacy Policy.

The Information About You We Collect and Process
Depending on how you use the Website and interact with us offline, we may collect several types of information from you, including the following:
 

Category	Examples	Collected
A. Identifiers	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, loyalty account number, social security numbers, driver’s license numbers, and other government-issued identification numbers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, physical characteristics or description, address, telephone number, or any financial 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, ethnicity, color, ancestry, national origin, citizenship, criminal record, trade union membership, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information, only as required by law.	Yes, if a customer chooses to provide it
D. Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, including fingerprints, or activity patterns used to extract a template or other identifier or identifying information.	No
F. Internet or other similar network activity	Browsing history, search history, information on a customer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Information about your physical location to, for example, locate stores near you.	Yes
H. Sensory data.	Information captured from audio, electronic, visual, or other forms of monitoring or surveillance.	Yes
I. Professional or employment-related information.	Job related data, maintained as part of the employment relationship that is present in a job application, current or past job history, performance evaluations, employment contracts, and other information.	No, not for customers.
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.	No, not for customers.
K. Inferences 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 Information

By providing us with your personal information, you consent to us processing this personal information in one or more of the ways described in this Privacy Notice.  We may use information that we collect about you or that you provide to us, including personal information, to provide products and services to you.  The purposes for which we collect your data are described in further detail in the sections of our Privacy Policy titled “How We Use Your Information”.

 

How We Collect Information About You

• Directly From You When You Provide It To Us.

1. When making an online or retail purchase.
2. When registering for a Standso Website account, for Standso marketing emails, for a Standso sweepstakes or giveaway, or for Standso loyalty program, either in person, at an event, or online.
3. If you contact our customer service department, you may need to provide us with additional information so we can respond to your questions and concerns as completely and thoroughly as possible.
4. In order to provide an enhanced customer experience, we may occasionally request additional information such as your gender, shopping preferences, product interest, and email notification preferences. Whether you provide this information is completely optional and up to you.

• Automatically As You Navigate Our Website. We use automatic data collection technologies, including those of service providers and third parties, to collect additional information about your equipment, browsing actions, and patterns including:

1. Details of your visits to our Website, including page views and clicks, search activity, cart activity, location data, transcripts of chats with customer service, and the resources you access and use on the Website.  This information allows us to see which areas of our Website are most visited, and helps us improve the quality of your online experience by recognizing and delivering more of the most desired features and services. To better understand and optimize the user experience, we also use service providers’ user session recording and website chat software and servers. For example, if a visitor to our website experiences a technical problem, we may review users’ session recordings to see how they used our website (for example, pages visited, mouse movements, links clicked, or information the user enters into webforms on our website) and other details about their system setups to help us more quickly and more accurately identify the cause of the problem so that we can resolve it for our customers.  When a visitor chats via our website with customer service, we use a service provider’s cloud-based software and servers to enable, process, and store this chat.  By using this chat feature, you consent to our use of these technologies and to the terms of this Privacy Policy. 
2. Information about your computer and Internet connection, such as browser type, browser version, operating system and IP address.
3. Information about your online activities over time and across third-party websites or other online services (behavioral tracking).
4. Why We Automatically Collect This Information. Automatically collecting this information helps us to maintain and improve our Website. It also allows us to verify system and server integrity and to provide you with more personalized service. For example, by using cookies or by logging in as a Standso member, we can recognize you when you return to our Website and provide you with a customized Website experience based on your stored preferences and individual interests.
5. How We Automatically Collect This Information. We automatically collect this information using cookies, web beacons, and other technologies, including those described above.

• A cookie is a small removable text file that is downloaded onto your computer, mobile phone, tablet or other device when you access a website. Standso uses three types of cookies: (1) cookies required to enable core site functionality such as log-in, the shopping cart, checking out, product searching, store locator services, and estimated shipping costs; (2) cookies that enable additional site functionality such as recognition of Standso membership and promotion codes; and (3) advertising cookies that are used by Standso and/or third-party companies to track your Website use and links you have followed in order to deliver content tailored to your interests both on our Website and elsewhere. Information collected by advertising cookies may be shared with third party advertisers.
• A web beacon is a small electronic file contained on pages of our Website that permits Standso to count users who have visited those webpages or opened an email.
• Third-Party Use of Cookies and Other Tracking Technology. Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks, and providers of external services like web traffic analysis services. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. We do not control these third parties’ tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information about your online activities over time and across different websites and other online services. They may also use this information to provide you with behavioral advertising or other targeted content. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. We also work with other companies who use cookies to serve ads on our behalf across the Internet. These companies may collect information about your visit to our website and about your interaction with our communications including advertising and emails.  You may choose to opt out of the sharing of personal information for purposes of targeted advertising or cross-context behavioral advertising by visiting our Do Not Sell Or Share Your Personal Information page Your Privacy Choices and clicking the box.

Disclosing Your Personal Information
We may disclose personal information that we collect or you provide as described in this Privacy Notice:

• To our subsidiaries and affiliates, which may require transferring your information outside of the United States.
• To our agents, contractors, business partners, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, advertising strategies, marketing and promotional material distribution, website usage evaluation, data analysis and, where applicable, data cleansing. We also may share non-personal information (such as the number of users who visited the website during a specific time period or who purchased a specific product through the website) with our marketing partners, advertisers and others from time to time. This information generally is shared in an aggregated form.
• To service providers, such as credit agencies, to verify delivery names and addresses for online orders. If you provide us with a delivery name and address which is not your own, you must have that person’s permission to give us their personal information and for us to use it for the purposes specified. By providing it, you are affirming that you have their permission to do so.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Standso’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Standso about our Website users is among the assets transferred. If that happens, your personal information may be disclosed to another company, but that disclosure will be subject to Stnadso’s Privacy Notice.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary to protect the rights, property, or safety of Standso or any of our respective affiliates, business partners, customers, or others.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

Standso does not sell or disclose sensitive personal information about you for targeted advertising purposes.
How Long We Keep Your Personal Information
Standso will retain personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for personal information, Standso will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  The length of time we retain personal information and sensitive personal information also depends on the form of the data we collect and on whether we have received a request to delete data that is not subject to an exemption. Standso complies with minimum retention periods required by federal and state law for the retention of certain information that is personal information.


Our Recent Data Practices

1. Personal Information Collected (By Categories Set Forth In CCPA). During the preceding 12 months, we have collected the following categories of personal information about California Consumers (including, but not limited to, customers, job applicants and/or employees):

• Identifiers (including, for example, names, email addresses, postal addresses, loyalty account numbers, and IP addresses);
• “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, physical characteristics (e.g., shoe size), address, and telephone numbers);
• Characteristics of protected classifications under California or federal law (for example, gender-related shoe or apparel sizes);
• Commercial information (such as records of products you purchased);
• Biometric information, defined in the CCPA to include an individual’s biological characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video);
• Internet or other electronic network activity information (such as website usage details, your IP address, or the equipment you use to access our website);
• Geolocation data (for example, a particular store at which you signed up for a Standso customer loyalty program or information about your location while visiting our web site that is used to identify stores near you);
• Audio, electronic, visual, thermal, olfactory, or similar information (such as images recorded on security video);
• Education information (if you choose to apply for employment at Standso);
• Professional or employment-related information (if, for example, you choose to apply for employment at Standso or if you purchase Standso products through a program with your employer);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting, for example, the consumer’s preferences, characteristics, or predispositions (for example, products you have viewed or added to your cart on our website).

2. 
   Personal Information Disclosed For A Business Purpose To Third Parties (By Categories Set Forth In CCPA).
   
   During the preceding 12 months, Standso has disclosed for business purposes the following categories of personal information to certain categories of third parties that are also identified below..   

Category of Personal Information	Third Parties
Category A: Identifiers	Shipping parties for order fulfillment services, payment processors, advertising providers and social networks, other website users (if you choose to share customer comments), government entities for compliance and legal purposes, third parties who provide certain employee benefits or services
Category B: California Customer Records personal information categories	Shipping parties for order fulfillment services, payment processors, advertising providers and social networks, corporate affiliates, other website users (if you choose to share customer comments), government entities for compliance and legal purposes, third parties who provide certain employee benefits or services
Category C. Protected classification characteristics under California or federal law	Third parties who provide certain employee benefits or services, government entities for compliance and legal purposes
Category D. Commercial information	Shipping parties for order fulfillment services, payment processors, data analytics providers, advertising providers and social networks
Category F. Internet or other similar network activity	Data analytics providers, advertising providers and social networks, internet service providers
Category G.  Geolocation data	Data analytics providers, advertising providers and social networks, internet service providers
Category K. Inferences drawn from other personal information.	Data analytics providers, advertising and social network providers

 

3. Sales and Sharing of Personal Information for Cross-Context Behavioral Advertising.

In the preceding twelve (12) months, Standso has not sold personal information for monetary consideration.  We may share, and in the preceding twelve (12) months have shared, Internet or other similar network activity, such as information regarding a consumer’s interaction with our websites, applications, or advertisements, with digital advertising platforms like Meta Platforms, Inc. or Google LLC.  We share this information to provide advertising that is targeted to the interests of our consumers (which also may be classified as a “sale” of personal information under California law).  Please see below for information on how you may opt out of this sharing.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.  An authorized agent may also submit requests asserting those rights on your behalf, subject to verification. 


To exercise your rights, you or an authorized agent may call (888) 969-2526, or submit a request by emailing us at info@standso.com. Please note that your request is subject to verification, and that we are not obligated to provide personal information in response to such a request if a consumer makes more than two requests in a 12-month period.

In order to verify that you are the consumer to whom the personal information relates, we may request certain information from you.  To obtain information about categories of personal information, we may request that you submit two data points that match data points that we maintain about you and that we determine are reliable for purposes of verifying your identity.  To obtain specific pieces of information we may have about you, we may request that you submit at least three pieces of personal information that we can match to information we maintain along with a signed declaration under penalty of perjury.  The type of verification we may require for a request to delete will depend on the nature of the information that you seek to delete. 

Access to Specific Information and Data Portability Rights
You have the right to request that Standso disclose certain information to you about our collection and use of your Personal Information since January 1, 2024, including the following:

• 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, selling, or sharing that Personal Information.
• The categories of third parties with whom we disclose that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold your Personal Information, the categories of Personal Information that each category of recipient purchased; and
• If we disclosed your Personal Information for a business purpose, the categories of Personal Information that each category of recipient obtained.

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Correction Request Rights
You have the right to request that Standso correct any inaccurate Personal Information about you maintained by the business.  To make such a request, you may either call (888) 969-2526 or submit a request by emailing us at info@standso.com.  Please note that your request is subject to verification.


In determining the accuracy of the personal information that is the subject of your request to correct, Standso will consider the totality of the circumstances relating to the contested personal information.  We may require you to provide documentation of the information’s inaccuracy, but we will only maintain that documentation for the purpose of processing your request and to comply with any legal obligations.

As an alternative to correcting the contested information that is the subject of your request, Standso may simply delete it.  Standso may also deny your request to correct if we have denied a request to correct the same alleged inaccuracy within a 6-month period, unless you provide new or additional information to prove that the information at issue is inaccurate. 

Deletion Request Rights
You have the right to request that Standso delete any of your Personal Information, and that we direct any service providers to do the same. To make such a request, you may either call (888) 969-2526 or submit a request by emailing us at info@standso.com. Please note that your request is subject to verification.
A request to delete your data is different than a request to unsubscribe from emails you may receive from Standso; unsubscribing from emails will not result in Standso deleting your Personal Information. Likewise, deleting your online account is not the same as a request to delete your Personal Information and will not result in a deletion of all your data from Standso1 systems. If you want Standso to delete your Personal Information, please submit a deletion request using the instructions provided above.

Standso will attempt to respond to your request to delete within 45 days of receiving your request, although we may require an additional 45 days. In order to be able to process returns, Standso may retain payment token data for up to 120 days. For record-keeping purposes, Standso will retain records of your request to delete, or any other request under the CCPA, and Standso’s response for a period of at least 24 months.

We also reserve the right to deny your request if your personal information is required to:

1. Complete the transaction for which the Personal Information was collected;
2. Provide a Product requested by you;
3. Continue the ongoing business relationship with you within the reasonably anticipated context of that relationship;
4. Perform a contract between you and Standso;
5. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
6. Debug to identify and repair errors that impair existing intended functionality;
7. Exercise free speech, ensure the right of another California resident to exercise his or her right of free speech, or exercise another right provided for by law;
8. Comply with the California Electronic Communications Privacy Act;
9. 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;
10. To enable solely internal uses that are reasonably aligned with the expectations of you based on your relationship with us;
11. Comply with legal obligations;
12. Otherwise to be used internally in a lawful manner that is compatible with the context in which you provided the Personal Information; or
13. Provide employment and related benefits.

Right to opt out
If you are a California resident, you have the right to opt out of having your personal information sold or shared to third parties. If you are a California resident under the age of 16 but at least 13, you have the right to only have your information sold or shared if you opt in and affirmatively authorize the sale of your personal information; if a California-resident child is less than 13, then the child’s parent or guardian must opt in and affirmatively authorize the sale or sharing of personal information. Our current practice is to not sell your Personal Information for monetary consideration and we have not done so in the preceding 12 months. As described above in this notice, we may disclose your personal information to third parties, such as when we pay a service provider to assist us with processing your Personal Information and receive that service in return.

To opt out of sales and sharing, please email us at info@standso.com or call us at 1-888-969-2526.  
If your browser supports the Global Privacy Control (“GPC”) signal, you can turn on the GPC signal to opt out of the sale or sharing of personal information that you share with us during that browsing session on our website.


Our website is not intended for California consumers under 16 years of age.  If you are such a consumer, please do not use this website.  We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. 

Right of non-discrimination
You have a right to exercise your rights under the CCPA without being subject to discrimination, including, but not limited to, by:

• Denying you goods or services;
• Charging you different prices or rates for goods or services;
• Providing you a different level or quality of goods or services; or
• Suggesting you will receive a different price or rate for goods or services or a different level of quality of goods or services.

This right does not prohibit a business from charging a consumer a different price or rate, or from providing a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the consumer’s data. In certain instances, we may need your information to provide you with a particular service.

 

Right to Limit Use And Disclosure Of Sensitive Personal Information

Other than the use or disclosure of Sensitive Personal Information to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, to perform the services set forth in California Civil Code § 1798.140(e)(2), (4), (5), or (8), or as otherwise authorized by regulations adopted pursuant to Civil Code § 1798.185(a)(19)(C), we do not use or disclose sensitive personal information.