California Consumer Privacy Act (CCPA) Privacy Notice

Our Commitment to Privacy

This privacy notice explains the categories of personal information we collect from our customers who are California residents (“you”), and the purposes for which such information will be used, the rights and choices that you have regarding your data, and how you may exercise your rights. If you are located outside of the State of California this privacy notice does not apply to you and you should refer to our Privacy Policy.

Personal Information Collection and Use
Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). In particular, we collected the following categories of personal information in the twelve (12) months preceding the Last Update:

Category

Examples

Identifiers

Name, shipping address, billing address, email address, phone number, online identifier, Internet Protocol address.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, billing address, mailing address, telephone number.

Some personal information included in this category may overlap with other categories.

Commercial information

Records of products or services purchased, obtained or other purchasing or consuming histories.

Inferences drawn from other personal information

Profile reflecting a person's consumer preferences or characteristics.

Internet or other similar network activity

Information on a consumer's interaction with a J.McLaughlin Web site, application, or advertisement.

Geolocation data

Physical location.

Categories of Sources

We collect the categories of personal information identified above from the following categories of sources: (i) directly from consumers (e.g., forms, surveys, responses, or other direct interactions from or with consumers),(ii) indirectly from consumers (e.g., consumer activity online, interactions with our Website and other sites), (iii) from website visitors about other consumers, (iv) social networks, (v) data analytics providers, (vi) advertising networks, (vii) data resellers/brokers, (viii) resellers/wholesalers/distributors, and (ix) other business partners and affiliate partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:


  • To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order to purchase a product, we will submit necessary personal information to the appropriate delivery company.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our Web site and present its contents to you.
  • As necessary or appropriate to protect the rights, property or safety of us, our consumers or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To support internal business processes, authentication, fraud prevention, and public safety and legal functions.

We 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.

Sharing Personal Information

We may disclose your personal information to the following categories of third party recipients.Service Providers. We may disclose your personal information to our service providers who are under contract and who help with our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with include:


  • Cloud storage
  • Payment processing
  • Customer support
  • Data analytics
  • Information technology
  • Delivery
  • Marketing

Advertising and Marketing Partners. We may disclose your personal information to advertising and marketing partners that include advertising agencies and networks that assist us with measuring, targeting, and placing advertisements, and marketing platforms and partners that help us develop and deploy marketing strategies.


In the twelve (12) months preceding the Last Update, we may have disclosed or sold the categories of personal information for a business purpose to the categories of recipients set forth in Table I.


Table I

Categories of Personal Information Collected

Categories of Recipients with Whom We Share this Personal Information for a Business Purpose

Categories of Recipients with Whom We Sell this Personal Information for a Business Purpose

Identifiers

Service Providers

Advertising and Marketing Partners

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e))

Service Providers

Advertising and Marketing Partners

Commercial Information

Service Providers

Advertising and Marketing Partners

Internet or other similar network activity

Service Providers

Advertising and Marketing Partners

Geolocation data

Service Providers

Advertising and Marketing Partners

Inferences

Service Providers

Advertising and Marketing Partners

California Privacy Rights

The California Consumer Privacy Act provides California residents with the following rights:

Right to Know

You have the right to know and see what data we have collected about you over the past 12 months, including:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collecting your personal information;
  • The categories of third parties with whom we have shared your personal information; and
  • The specific pieces of personal information we have collected about you.

Right to Delete

You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, which include, but are not limited to, when the information is necessary for us or a third party to do any of the following:


  • Complete your transaction;
  • Provide you with product or service;
  • Perform a contract between us and you;
  • Protect your security and prosecute those responsible for breaching it;
  • Fix our system in the case of a bug;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
  • Comply with a legal obligation; or
  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Personal Information.

If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your personal information (the “right to opt-out”). We do not knowingly sell the personal information of children under the age of 16, unless we receive affirmative authorization (the “right to opt-in”) from either (i) the consumer who is between 13 and 16 years of age, or (ii) the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Your Additional California Rights

Under California’s “Shine the Light” Law (Civ. Code Sec. §1798.83) you can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding 12 months. The request under California’s “Shine the Light” law is free and may be made once in a 12-month period.

No 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 with a different level or quality of goods or services.
  • Suggest that you may receive a difference price or rate for goods or services or a different level or quality of goods or services.
Notice of Financial Incentive

Via J.McLaughlin’s web page, you can sign up to receive emails from us. In return for your email address, we will provide you with a one-time 15% discount off your next full-price purchase. Because this offering and future offerings like it involve the collection of personal information in exchange for rewards and other perks, they may be interpreted as “financial incentives” under the CCPA. These financial incentives are reasonably related to the value of the personal information you provide. We calculate the value of our offers and financial incentives based on the expense related to offering these benefits to participants. For example, a good-faith estimate of the value of the personal information obtained through a one-time 15% discount incentive described above is equal to 15% of the full-price purchase.

Exercising Your Rights to Know and Delete

To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:


Toll Free Number: You may call our Toll Free Number at 833-796-0136 PIN:714818


Website: You may visit https://www.jmclaughlin.com/contact-us to authenticate and exercise rights via our website and web form.


The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) 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 related to you. Upon receipt of a CCPA request, J.McLaughlin will verify that an appropriate number of items of personal information provided by the requestor match personal information maintained by J.McLaughlin.  As appropriate, J.McLaughlin may also ask a requestor to sign a declaration which states that the requestor is the consumer whose personal information is the subject of the request.


If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

Response Timing and Format

We will confirm receipt of a request to a verified customer within 10 days of receiving the same.


We aim to respond to a verified consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. We will deliver our written response by mail or electronically. 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 may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request

Exercising Your Right to Opt-Out of the Sale of Personal Information

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:


Do Not Sell My Personal Information


Once you make an opt-out request, we will not ask you to reauthorize personal information sales for at least twelve (12) months. However, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@jmclaughlin.com.


You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Retention of Personal Information

We will keep the personal information that you provide to us for the period of time that your account is active. We only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of satisfying any legal, accounting, or reporting obligations or to resolve disputes.

Changes to Our Privacy Notice

This privacy notice is effective as of the date of the Last Update stated at the top of this privacy notice.  We may change this privacy notice from time to time with or without notice to you. By visiting or accessing the website, purchasing products from us, or otherwise engaging or interacting with us after we make any such changes to this privacy notice, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the privacy notice in current effect.  Please refer back to this privacy notice on a regular basis.

Contact for More Information

If you have further questions about J.McLaughlin’s CCPA practices, please email privacy@jmclaughlin.com