This Privacy Policy for California Residents supplements the information contained inTraina Home Grown®’ General Privacy Policy and applies solely to residents of the State of California (“consumers” or “you”). Traina Home Grown® has adopted this policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this policy.
Information We Collect
At times we collect personal information from consumers. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
• Publicly available information from government records, or
• Deidentified or aggregated consumer information.
Personal information can be broken down into 11 different categories. The following table shows which types of personal information we have collected from consumers in the past twelve (12) months:
CATEGORY OF PERSONAL INFORMATION
EXAMPLES
COLLECTED
CATEGORIES OF THIRD-PARTIES WHO MAY RECEIVE INFORMATION
BUSINESS PURPOSE
A. Identifiers.
A real name, alias, postal address, unique
personal identifier, online identifier,
Internet Protocol address, email address,
account name, Social Security number,
driver’s license number, passport
number, or other similar identifiers.
YES
Data analytic
providers; Data
brokers or
aggregators;
Service providers;
Affiliated
companies;
Internet cookie
data recipients like
Google Analytics
Disclosed to service
providers to run
payments and
fulfill/ship orders. To
respond to your
inquiries or address
your complaints. To
create, maintain and
secure your account
with us; Send email
notifications of
promotions or new
products; To notify you
of changes to our
website; To provide
you with a customized
user experience; To
improve our business
operations, websites,
marketing and social
media; For marketing,
research, legal, and
other business
purposes; To comply
with legal obligations.
B. Personal
information
categories listed in
the California
Consumer
Records statute
(Cal. Civ. Code §
1798.80(e)).
A name, signature, Social Security
number, physical characteristics or
description, address, telephone number,
passport number, driver’s license or state
identification card number, insurance
policy number, education, employment,
employment history, bank account
number, credit card number, debit card
number, or any other financial
information, medical information, or
health insurance information.
Some personal information in this
category may overlap with other
categories.
YES
Data analytic providers; Data
brokers or aggregators;
Service providers; Affiliated
companies; Internet cookie
data recipients like Google Analytics.
Disclosed to service
providers to run
payments and
fulfill/ship orders. To
respond to your
inquiries or address
your complaints. To
create, maintain and
secure your account
with us; Send email
notifications of
promotions or new
products; To notify you
of changes to our
website; To provide
you with a customized
user experience; To
improve our business
operations, websites,
marketing and social
media; For marketing,
research, legal, and
other business
purposes; To comply
with legal obligations.
C. Protected
classification
characteristics
under California
or federal law.
Age (40 years or older), race, color,
ancestry, national origin, citizenship,
religion or creed, marital status, medical
condition, physical or mental disability,
sex (including gender, gender identity,
gender expression, pregnancy or
childbirth and related medical
conditions), sexual orientation, veteran or
military status, genetic information
(including familial genetic information).
NO
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
To respond to your
inquiries or address
complaints, To provide
you with a customized
user experience; To
improve our business
operations, website,
and social media; For
marketing, research,
legal, and other
business purposes; to
provide you with a
customized user
exerpience; to comply
with our legal
obligations.
E. Biometric information.
Genetic, physiological, behavioral, and
biological characteristics, or activity patterns used to extract a template or
other identifier or identifying information, such as fingerprints,
faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise
data.
NO
F. Internet or
other similar
network activity.
Browsing history, search history,
information on a consumer’s interaction
with a website, application, or
advertisement.
YES
Data analytic
providers; Data
brokers or
aggregators;
Service providers;
Affiliated
companies;
Internet cookie
data recipients like
Google Analytics
To analyze and track
usage of our website,
and social media
accounts; To better
understand how you
use our site and which
products may interest
you; To enhance,
modify, or improve our
website, our products,
and our business; To
send promotional
communications; For
marketing, research,
legal and other
business purposes; To
comply with legal
obligations.
G. Geolocation data.
Physical location or movements
YES
Data analytic
providers; Data
brokers or
aggregators;
Service providers;
Affiliated
companies;
Internet cookie
data recipients like
Google Analytics
To analyze and track
usage of our website,
and social media
accounts; To enhance, modify, or improve our website, and our business; For
marketing, research,
legal and other
business purposes; To comply with legal
obligations.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employmentrelated information.
Current or past job history or performance evaluations.
NO
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 directly related to a
student maintained by an educational
institution or party acting on its behalf,
such as grades, transcripts, class lists,
student schedules, student identification
codes, student financial information, or
student disciplinary records.
NO
K. Inferences
drawn from other
personal
information.
Profile reflecting a person’s preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
We obtain the categories of information listed above from the following sources:
- Information you provide us. For example, forms you complete or products and services you purchase.
- Automatic data collection. For example, observing details of your visits to our website, details regarding general geographic location, and information about your computer, internet connection, operating system or browser type.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To process and/or fulfill your order. This includes but is not limited to processing payments, shipping products, responding to inquiries, etc.
- To create, maintain and secure your account with us, if you choose to create an account, and to provide you with notices about your account.
- To provide you with support or information that you request from us, and respond to your questions, comments or to investigate and address your complaints.
- To notify you of products and promotions that may be of interest to you, if you subscribe to our email lists.
- To personalize your website experience and to deliver content and products and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites and via email.
- For data analysis regarding the locations of our website users.
- To comply with applicable law, court order, or governmental regulations, or to respond to law enforcement requests.
- To carry out our obligations and enforce our rights arising from any contracts entered into, between you and us, including for billing and collection.
- To evaluate or conduct a merger, restructuring, reorganization or other sale or transfer of some or all of our assets should such an event occur.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information for Business Purposes
We may disclose your personal information to a third party for business purposes. See the table above for a list of categories of information we have disclosed to third party service providers in the preceding twelve (12) months.
Our use of tracking technologies may be considered a “sale” under California law. You may opt-out of being tracked by these third parties by clicking the “Do Not Sell My Personal Information” link on our website. See the table above for a list of categories of information we have disclosed that may be considered a sale in the preceding twelve (12) months.
We do not knowingly disclose information about individuals under the age of 16. The following are categories of third parties to whom we may disclose your information. See the table above for the type of information we disclose to each type of third party:
- Service providers, including but not limited to:
- Companies that provide shipping and delivery services.
- Companies that process credit card payments. When you enter your payment information into our website, the information goes directly to the payment portal. We are never directly in possession of your payment information.
- Data aggregators — companies that compile data from our website and provide information such as the number of visitors, whether visitors are returning or new, and general geographic locations. The information we receive does not directly identify any individual.
Your Rights
The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You may make this request no more than twice in a twelve (12) month period (the “right to know”). Once we receive your request and confirm your identity, 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 (data portability request).
- If we sold (as defined by California law) or disclosed your personal information for a business purpose, you will receive two separate lists. One, identifying the disclosure, the category of information disclosed and the category of each recipient of the information. The other identifying disclosures that may be considered a sale under California law, which identifies the personal information, categories that each category of recipient obtained.
Right to Request Deletion
You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
- 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 et. seq.).
- 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 the information that are compatible with the context in which you provided it.
How to Exercise Your Rights
Making Access and Deletion Requests
To make a request to access your information or to request that we delete your information please contact us by either:
- Emailing us at CustomerCare@traina.com or,
- Call us toll free at 1-866-470-0358
Only you, or someone legally authorized to act on your behalf, may make a request related to your information. You may make a request on behalf of your minor child. You may only submit a request to know twice within a 12-month period.
When making your request you must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or you are authorized to collect information on that person’s behalf.
To verify your request you may be asked to provide a copy of your driver’s license or other government issued identification card, and valid documentation of your right to request information on another’s behalf if you are not the person about whom the information was collected.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Please note that 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.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. For example, we will not do any of the following:
- 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.
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated policy here and update the policy’s last modified date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this policy, the ways in which Traina Home Grown® collects and uses your information, 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: 1-866-470-0358
Email: CustomerCare@Traina.com
Mail:
Traina Home Grown®
Attn: Customer Care Service
P.O. Box 157
Patterson
California, 95363