California Consumer Privacy Act
Effective Date: 1/1/2020
Last Reviewed on: 1/1/2020
This Privacy Notice for California Residents supplements the information contained in the EJ Group, Inc. (“EJ”) (“us”, “we” or “our”) Privacy Policy together with Terms of Use of the Website (the “Website”), Cookie Policy and the documents referred to in them, sets out the basis on which any personal data we collect from you or that you provide to us will be processed. It applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with California’s “Shine the Light” law as well as the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this notice.
Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed at the end of this notice and specify you are making a Shine the Light request.
The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following notice.
Personal Information We Collect
Our Website 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, the EJ website, www.ejco.com (“Website”), and other sources of Personal Information have collected the following categories of Personal Information from its consumers within the last twelve (12) months, and we have used it for the following business purposes:
| CATEGORY | ELEMENTS WE COLLECT | BUSINESS PURPOSE FOR COLLECTION |
|---|---|---|
| A. Identifiers. | Consumer contact information: Name, postal address, shipping address, email address, account information, employee ID. | We collect this information so that we can correspond with customers about our products and answer your questions. For example, we use this information to provide marketing materials to customers, respond to product requests, develop price quotes, process orders and shipments, payments, returns, and service requests and other information requests. |
| Employee contact information: Name, postal address, employee ID, drivers license numbers for Company drivers. | Create and maintain employee records. We also use this information about our employees for communications and other purposes associated with our employment relationship. | |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, postal address, shipping address, email address, telephone number, bank account number, credit card number. | Create and maintain customer accounts. |
| A name, social security number, telephone number, bank account number, education, employment history, current employment, wages, dependents, dependent information, health and life insurance information. | Create and maintain employee records. | |
| D. Commercial information. | Records of products or services purchased, obtained, or considered, customer survey data, or other purchasing or consuming histories. | To process your information requests, purchases, transactions, and payments. |
| E. Biometric information. | Fingerprint or facial recognition. | Employee authentication on computing devices. |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | To provide, support, personalize, and develop our Website, products, and services, and deliver content and product service offerings relevant to our customer’ interests. To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business. |
| I. Professional or employment-related information. | Current or past job history may come from employment applications. Performance evaluations are kept. | Hiring, employee development and employment records. |
| 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)). | College courses qualifying for reimbursement. | Employee development. |
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Sources of Personal Information
EJ obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete for credit, or for products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
- Purchased marketing databases. For example, to identify consumers in our industry who may be interested in our products and services.
- Tradeshow attendee lists
- Business acquisitions
- Online research
- Web site visitors from paid search ads
- Social media posts
- Employee applications and other employment forms upon becoming an employee
Sharing Your Personal Information
We do not sell, trade, or rent Personal Information to others and we have not done so during the preceding twelve (12) months. However, we may disclose your Personal Information to third parties for business purposes. Specifically, we disclose the following categories of personal information for a business purpose:
| Category of Personal Information Disclosed | Category of Third Parties with Whom Information is Disclosed |
|---|---|
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, bank account and routing number. | Banks for customer payment receipts or vendor payments, and for employee payroll and expense reimbursements. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Company employee ID number, email, bank account and routing number. | Employee expense processing and approvals. |
| Commercial information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories. | Auditors for confirmation of business practices. |
| Internet or other similar network activity: Browsing history, search history, viewing history, information on a consumer's interaction with a website, application, or advertisement. | Analytics providers to support business operations improvements and to develop business strategies. |
| Identifiers: Employee name, employee ID; Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Social security number, date of birth, current employment, wages, dependents, dependent information, health and life insurance information. |
Benefits administrators for employee benefit management. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, Social Security number, address, telephone number, bank account and routing number. | Payroll processors for employee wages and pay supplements. |
| Commercial information: Name and shipping address. | Partners for shipping product on a need to know basis only. |
| Identifiers: All types; Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), and Commercial information: All types; Commercial information: Customer survey data; Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): College courses qualifying for reimbursement. |
Service providers to host or process Company data and support Company 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. |
| Identifiers: Email addresses. | Services to verify email addresses are valid. |
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EJ, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
The Right of Access
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.
You have the right to request that EJ disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and verify your request, 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.
- Or such other information as permitted by the CCPA.
The Right of Deletion
You have the right to request that EJ delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your deletion request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception under the CCPA 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.
- 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 Your Rights
To exercise your rights under the CCPA, please submit a consumer request to us by using our CCPA rights submission form or by contacting us at either:
- Calling the Office of Corporate Compliance at 1-844-218-3380
- Emailing us at corporatecompliance@ejco.com
We may not discriminate against you if you choose to exercise your rights.
Only you, or your authorized agent, may make a consumer request related to your Personal Information. You may also make a request on behalf of your minor child.
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. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and contact information. We may ask for additional information to verify your identity.
We will only use Personal Information provided in a request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to your 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.
We will deliver our written response by mail or electronically.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data access 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.
Changes to Our Privacy Notice
EJ 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 notice on the Website and update the notice's effective 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 notice, the ways in which EJ collects and uses your Personal 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:
- Calling the Office of Corporate Compliance at 1-844-218-3380
- Emailing us at corporatecompliance@ejco.com
- Completing the CCPA rights submission form
