Thick Head California Privacy Notice

Effective Date: March 3, 2021

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to THICK HEAD, LLC’s (“Company” “us” “we” our”) other privacy policies or notices. In the event of a conflict between any other Company policy, statement or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA. This Notice also covers rights California Consumers have under the CCPA as well other notices to Californians required by other laws. The description of our data practices in this Notice, as required by the CCPA, covers only calendar year 2020 and will be updated annually. Our practices in calendar year 2021 may change, however, if materially different such that we think a Consumer would reasonably expect notice we will provide notice in connection with the applicable collection, which may include reference to other applicable privacy policies and notices.

Consistent with the CCPA, job applicants, current and former employees and independent contractors (“Personnel”), and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered “Consumers” for purposes of this California Privacy Notice or the rights described herein. However, our Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department here.

To aid in readability, in some places we have abbreviated or summarized CCPA terms or language, but a full copy of the CCPA is available here for your review, and in some places in this Notice we cite and/or link to specific CCPA sections for your reference. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

You can click on the following blue links to navigate to the different sections in this Notice.

Table of Contents

  1. PI We Collect
  2. Sharing of PI
  3. California Privacy Rights
  4. Additional California Notices
  5. Contact Us
  1. PI We Collect.

    We collect PI about California Consumers including:

    Category of PI Examples of PI Sources of PI Business or Commercial Purposes for PI Collection
    1. Identifiers
    (as defined in CCPA §1798.140(o)(1)(A))
    This may include, but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, or email address Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance
    2. Personal Records
    (as defined in CCPA §1798.140(o)(1)(B))
    This may include, but is not limited to: telephone number, credit card number, or debit card number. Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance
    3. Customer Account Details / Commercial Information
    (as defined in CCPA §1798.140(o)(1)(D))
    This may include, but is not limited to: products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance
    4. Internet Usage Information
    (as defined in CCPA §1798.140(o)(1)(F))
    This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, or advertisement. Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance
    5. Geolocation Data
    (as defined in CCPA §1798.140(o)(1)(G))
    This may include, but is not limited to: precise physical location or movements and travel patterns. Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance
    6. Sensory Data
    (as defined in CCPA §1798.140(o)(1)(H))
    This may include,but is not limited to: audio recordings of customer care calls. Consumers directly Auditing, security, debugging, processing interactions and transactions, performing services, quality assurance

    As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information. We have no obligation to re-identify such information or keep it longer than we need it to respond to your requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers.

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  2. Sharing of PI.

    We may share PI with our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), affiliates, and/or third parties to which we sell your PI, including without limitation during calendar year 2020 as follows:

    Category of PI Shared with Third Parties? Categories of Third Parties
    1. Identifiers
    (as defined in CCPA §1798.140(o)(1)(A))
    Yes Advertisement networks, social networks
    2. Consumer Characteristics
    (as defined in CCPA §1798.140(o)(1)(C))
    No Advertisement networks, social networks
    3. Internet Usage Information
    (as defined in CCPA §1798.140(o)(1)(F))
    Yes Advertisement networks, social networks
    4. Geolocation Data
    (as defined in CCPA §1798.140(o)(1)(G))
    Yes Advertisement networks, social networks
  3. California Privacy Rights

    We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA we do not include that PI in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a Verifiable Consumer Request. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

    We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not. We reserve the right to direct you to where you may access and copy responsive PI yourself. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

    Consistent with the CCPA and our interest in the security of your PI, we will not deliver to you your Social Security number, driver’s license number or other government-issued id number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a CCPA request; however, you may be able to access some of this information yourself through your account if you have an active account with us.

    Your California Consumer privacy rights are as follows:

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  4. Additional California Notices

    In addition to CCPA rights, certain Californians are entitled to certain other notices, including:

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  5. Contact Us

    For more information on your California privacy rights contact us at 1-800-552-0281 or email us here. Or, write to us at:

    THICK HEAD, LLC
    P.O. Box 1366
    Hoboken, NJ 07030

    Attention: Legal Counsel

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