PRIVACY POLICY SUPPLEMENT FOR CALIFORNIA RESIDENTS

EFFECTIVE AS OF JANUARY 1, 2020

We at Litehouse, Inc. (“Litehouse”, “we,” “us,” or “our”) created this privacy policy supplement (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Notice for California Residents (“Privacy Notice”) supplements and is expressly made part of the information contained in Litehouse’s General Privacy Statement located at https://www.litehousefoods.com/privacy-statement and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

  1. Information We Collect.

Litehouse collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Litehouse has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category/Collected

  1. Identifiers. YES
  2. Commercial information. YES
  3. Internet or other similar network activity. YES
  4. Geolocation data. YES
  5. Professional or employment-related information. YES
  6. Inferences drawn from other personal information. YES

 

Category of Personal InformationCategories of Sources of Personal DataBusiness or Commercial Purposes for Collection and Use of Personal DataCategories of Third Parties with Whom Personal Data is Shared
Identifiers, such as email address, names, contact information, social networking information;·      Directly from you

·      [Indirectly from you.]

·      [From third-party business partners]

·      [TBD]·      Service Providers

·      Data Aggregators

·      [TBD]

Commercial Information, such as [insert description of personal information]·      Directly from you

·      [Indirectly from you.]

·      [TBD]

[TBD][TBD]
Internet or Electronic Network Activity Information, such as [your browser type, operating system, pages viewed, and hyperlinks clicked]·      Directly from you

·      [Indirectly from you.]

·      [TBD]

[TBD][TBD]
Professional or employment-related information, such as [your job history]·      Directly from you

·      [Indirectly from you.]

·      [TBD]

[TBD][TBD]
Inferences, such as [your preferences or approximate location]·      Directly from you

·      [Indirectly from you.]

·      [TBD]

[TBD][TBD]
Geolocation data, such as [the exact location of your device]·      [TBD][TBD][TBD]

Personal information does not include:

  • Publicly available information from government records.
  • De-identified 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; 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.

 

Litehouse obtains the categories of personal information listed above from the following

categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our websites.
  • From third-party business partners such as social media sites, ad networks, and analytics providers.
  1. How We Use Your Information. We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We may use or disclose the personal information we collect for one or more of the following business 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 Websites, products, and services.
    • 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 Websites, 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 Websites, products and services, databases and other technology assets, and business.
    • For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
    • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • To send you offers and promotions for our products and services.
    • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Litehouse will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

  1. Sharing Personal Information. Litehouse may disclose your personal information to a third party for a business purpose. We do not disclose your Personal Information to third parties for their direct marketing purposes. Rather, we, like many businesses, sometimes hire other companies to perform certain business-related functions on our behalf. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. Be advised that when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Litehouse has disclosed to a third party the following categories of personal information for a business purpose:

  • Identifiers.
  • Commercial information.
  • Internet or other similar network activity.
  • Inferences drawn from other personal information.
  1. In the preceding twelve (12) months, we have not sold personal information, and we will not sell your personal information. Your Rights and Choices. The CCPA provides consumers (California residents) 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 Litehouse 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 (seeExercising Access, Data Portability, and Deletion Rights), 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.

We will disclose this information in writing and will deliver the information by mail or electronically, at your option, in a readily usable format that allows you to transmit the information from one entity to another.

Deletion Request Rights

You have the right to request that Litehouse 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 Exercising Access, Data Portability, and Deletion Rights), 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 us or our service provider(s) to:

  • 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.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
  • 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • 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 us by either:

Calling us toll-free at 1-800-669-3169, or

Submitting a request to our website, available here:  _____TBD____, or

Emailing us at ccpa@litehouseinc.com.

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. To designate an authorized agent, you must provide [sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf.]

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

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • 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.

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

We endeavor to respond to a verifiable consumer request within forty-five (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.

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.

  1. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  2. Notice of Financial Incentive. You have the right to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights.  However, the CCPA allows us to offer certain financial incentive programs that may result in different prices, rates, or quality levels as long as we obtain your prior opt-in consent and the difference in price, rates or quality levels is directly related to the value that is provided to us by your personal information. We currently provide the following financial incentive program(s): [insert (1) name of financial incentive program, (2) a succinct summary of the financial incentive or price or service difference offered, (3) a description of the material terms, including the categories of personal information implicated, (4) how the consumer can opt-in, (5) notice of right to withdraw from the program and how to exercise that right, and (6) explanation of why this program is permitted under the CCPA, including: (a) a good-faith estimate of the value of the consumer’s data that forms the basis for offering the financial incentive or price or service difference; and (b) a description of the method the business used to calculate the value of the consumer’s data].
  3. Other California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites 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 ccpa@litehouseinc.com.
  4. Changes to Our Privacy Notice. Litehouse reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Websites and update the Privacy Notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.
  5. Contact Information. If you have any questions or comments about this Privacy Notice, the ways in which Litehouse collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-669-3169

Email: ccpa@litehouseinc.com

Postal Address: Litehouse Inc., 100 Litehouse Drive, Sandpoint, ID 83864