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California Consumer Privacy Act

Effective Date: January 1, 2020

  1. Introduction

This Privacy Notice for California Residents supplements the information contained in Twinings North America, Inc.’s (“Twinings North America,” “we,” “us,” or “our”) general Privacy Policy for websites and applications (“Privacy Policy”) and describes our privacy practices with respect to individuals who reside in the State of California (“consumers” or “you”).  

This Privacy Notice does not apply to information we collect when:

  • You are acting as a job applicant to us;
  • You are acting in your capacity as a current or former employee, owner, director, officer, medical staff member, or contractor for us;
  • You have been designated as an emergency contact for one of the persons listed above and your information has been collected for use solely within that context; or
  • We need your personal information to administer benefits obtained through one of the persons listed above.

We adopt this notice to comply with the California Consumer Privacy Act of 2018, as may be amended, replaced, or superseded as well as any implementing regulations (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice.  

This Privacy Notice does not disclose our practices with respect to B2B personal information.

  1. Information we collect about California consumers

See Section 2 of our Privacy Policy for the types of personal information we collect from you and Sections 4-6 and 8 of the Privacy Policy for why we collect this information.  For CCPA purposes, we collect the following categories of personal information: 

Category

Examples

 Do we collect this information?

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

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

A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, or any other financial information, medical information, or health insurance information.

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

NO

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 products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

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

G. Geolocation data.

In some cases, we may collect your location to provide you location-related services

YES

H. Sensory data.

If you call our offices and leave a voicemail, audio information

YES

I.   Professional or employment-related 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, including taste preferences, color preferences, and purchasing preferences.

YES

  • We do not sell your personal information

We do not, and will not, sell personal information of consumers and have not sold any such personal information within the last twelve (12) months.

  1. Notice of personal information that we have collected or disclosed in the last 12 months

For each of the categories of information we collected, as noted in Article II above, we shared this personal information with the following categories of third parties:

  • Service providers and vendors
  • Taxing entities
  • Insurance companies
  • Legal counsel
  • Our parent and affiliated companies who directly support our activities
  1. Your Rights and Choices
  1. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your personal information over the past 12 months. Note that our Privacy Policy and this Privacy Notice are intended to already provide you that information.  Even so, if you wish to exercise this right, see Exercising Access, Data Portability, and Deletion Rights below).

  1. Deletion Request Rights

You have the right to request that we 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 below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

  1. Exercising Access, Data Portability, and Deletion Rights
  1. How to submit requests: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  • Calling us at 1.800.803.6695 Please let the person answering the telephone know that you are calling about your California consumer privacy rights.
  • Completing the California Request Form and emailing it to us at: consumer.service@twiningsusa.com. If you email us, please insert “CCPA REQUEST” into the subject line of your email.
    1. Who may submit requests - Only you, or someone legally authorized 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. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.
    2. How often you can submit requests - You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
    3. How we verify and respond to requests - Your request must be verifiable. The 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, which may include requiring you to provide us at least two data points, depending on the type of personal information you are requesting to know or are requesting to be deleted.
  • Describe your request with enough detail that allows us to properly understand, evaluate and respond to it.

Note that we will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  1. 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, we will inform you of the reason and extension period in writing within forty-five (45) days of receiving your verifiable consumer request. We will deliver our written response by mail or electronically, at your option. 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.

  • 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. At this time, we do not engage in this type of disclosure.

  • Who to contact for more information?

For questions or concerns about our Privacy Policy, this Privacy Notice or our practices, you can contact us as provided in Section 14 of our Privacy Policy

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