Important Information for California Residents

Effective Date: December 31, 2019

 

We (2035 Sunset Lake Road, Newark, Delaware 1970, USA, “we” or “us”) are providing this supplemental privacy notice to give California residents the additional information required by the California Consumer Privacy Act (the “CCPA”).

We are committed to protecting the privacy and security of all the personal information that is entrusted to us. We have a Global Privacy Policy that protects your personal information no matter how or where it is collected, used, or stored. We also comply with applicable privacy and security laws, including the CCPA. This Privacy Notice describes our privacy and security practices in detail.

  1. Your Rights
    The CCPA provides California residents with specific privacy rights, including the right to receive a privacy notice, the right to know what information we have collected about you during the past 12 months, and the right to know what categories of personal information we have shared with third parties. CCPA gives California residents with the right to opt-out of having their personal information sold1. CCPA also gives California residents the right to request the deletion of your personal information.
    This notice provides information about the categories of information that we collect from California residents generally, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes. We do not sell personal information, so we do not offer a “do not sell” option. We do offer a number of other privacy choices, including the ability to opt-out of receiving marketing communications from us and the ability to control the third-party cookies that are placed by our website. Our Privacy Notice contains a description of all your choices.If you are a California resident, you may exercise your CCPA rights or authorize another person to act on your behalf by submitting your request under CCPA
  2. Please note that we may need to verify your identity before we can fulfill your request. Because we maintain limited personal information about consumers, commonly consisting of email marketing subscription information, we will generally verify your identity using your email address. We will respond to requests using the email address that is associated with the information we maintain. If you have purchased products from our online store, we may also verify you using our transaction records.
    If you would like to designate an agent, please send an email from your own email address to support@smart3d.tech indicating the name and email address of your agent. We will respond to that person’s requests using both your email address and the agent’s email address.
    The CCPA Rights Portal provides information about how you can request the deletion of your personal information. Please understand that we cannot delete personal information in those situations where our retention is required for our internal business purposes or otherwise permitted by CCPA (such as for fraud prevention or legal compliance). In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
    We do not offer financial incentives for the collection or sale of personal information. If you ask us to delete your information, we will not discriminate against you if you exercise your rights under CCPA.

Category and Sources of Personal Information

Representative Data Elements

Purpose for Collecting and Sharing the Personal Information

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose

Contact Information
We collect this type of information from:

  • You
  • Social media sites

Data elements in this category include:

  • Name
  • Username
  • Phone number
  • Email address
  • Mobile number
  • Mailing address

We use this type of information to identify you and communicate with you, including:

  • To send transactional messages (such as when you sign up for newsletters)
  • To send marketing communications, surveys and invitations
  • To enable delivery of ads on social media platforms
  • To personalize our communications and provide customer service
  • For our Everyday Business Purposes (2)

We may disclose this type of information to our Affiliates and Service Providers, including to social media companies such as Facebook which use the data only to identify which of our customers use their platforms so that we can deliver ads to you on the platform, and to:

  • Third parties who deliver our communications, such as the postal service and couriers
  • Third parties who assist us with address hygiene and fulfillment
  • Other third parties (including government agencies) as required by law

Relationship Information

We collect this type of information from:

  • You when you interact with us by signing up for emails; liking our content on social media; visiting us at a trade show; entering a contest; purchasing from our store, or registering a product that you have purchased.
  • We may collect information from social media sites when you post it publicly, such as when you post product reviews, or from other publicly available sources.
  • We may also infer information about you based on the information that you have given us or made public. For example, we may identify you as an influencer based on your public postings on social media sites.

Data elements in this category include:

  • Personal characteristics, such as your age or gender
  • Country or language preference
  • Data from social media profiles, such as Facebook, Twitter, and similar platforms
  • Data from our user communities
  • Marketing preferences
  • Household demographic data, including from real estate records and census data

We use this type of information:

  • To better understand you and our customers generally
  • To personalize our communications
  • To identify prospective customers
  • To identify influencers
  • For internal business purposes, such as quality control, training, and analytics
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Third parties with whom we have joint marketing and similar arrangements
  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Transaction and Interaction Information

We collect this type of information from:

  • You, when you interact with us, such as entering a contest or if you purchase products directly from us.
  • Third parties that process transactions for us.

Data elements in this category include:

  • Customer account information, purchase history, and related records
  • Customer identification numbers
  • Customer service records
  • Records related to downloads and purchases of products applications, including website and app usage and records relating to in-app purchases
  • Visitor Logs
  • Non-biometric data collected for consumer authentication (passwords, account security questions)

We use this type of information:

  • To fulfill our business relationship with you, including customer service and fraud prevention
  • For internal business purposes, such as finance, quality control, training, reporting, and analytics
  • For record-keeping and compliance, including dispute resolution
  • For risk management, fraud prevention, and similar purposes
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Third parties as needed to complete the transaction, including delivery companies, agents, and other publishers
  • Third parties with whom we have joint marketing and similar arrangements
  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Online & Technical Information

We collect this type of information from:

  • You and from your computer or devices when you interact with our platforms, websites, and applications. For example, when you visit our websites, our server logs record your IP address and other information.
  • Automatically, via technologies such as cookies and web beacons, when you visit our website or other websites.
  • Third parties, including computer security services and advertising partners.

Data elements in this category include:

  • IP Address
  • Device identifiers
  • Web Server Logs
  • First and Third-Party Cookies
  • Web beacons and pixel tags
  • Application logs
  • MAC Address, SSIDs or other device identifiers or persistent identifiers
  • Device Characteristics

We use this type of information:

  • For system administration, including optimizing our websites and applications
  • For information security and cybersecurity purposes
  • For recordkeeping, including logs and records that are maintained as part of Transaction Information
  • To better understand our customers and prospective customers and to enhance our Relationship Information, including by associating you with different devices and browsers that you may use
  • For online targeting and advertising purposes
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers including to companies such as Google which use the data collected by cookies and similar means to help us with our online advertising programs and to:

  • Third parties who assist with our information technology and security programs, including companies such as network security services who retain information on malware threats detected
  • Third parties who assist with fraud prevention, detection, and mitigation
  • Third-party network advertising partners
  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Audio Visual Information

We collect this type of information from:

  • You
  • Automatically, such as when we record calls to our call center.
  • Third parties that provide access to the information you make publicly available, such as social media.

Data elements in this category include:

  • Photographs
  • Video images
  • CCTV recordings
  • Call center recordings and call monitoring records
  • Voicemails

We use this type of information:

  • For internal business purposes, such as call recordings used for training, coaching, or quality control
  • For relationship purposes, such as the use of photos and videos for social media purposes
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Third parties who assist with our information technology and security programs, and our loss prevention programs.
  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Financial information

We collect this type of information from:

  • You, if you purchase products directly from us.

Data elements in this category include:

  • Payment card information

For security purposes, we do not generally store payment card numbers, CVV codes, or expiration dates.  These data elements are provided to our payment processors and not retained by us.

Financial information is maintained in our transaction data. We use this type of information:

  • For processing payments
  • For risk management, fraud prevention, and similar purposes
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Payment processors, financial institutions, and others as needed to complete the transactions and for authentication, security, and fraud prevention
  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Government-issued identification information numbers

We collect this type of information from:

  • You

We collect Social Security numbers from individuals as needed to comply with the law, such as tax reporting for individuals if the case be.

We use this type of information:

  • To comply with laws regulating sweepstakes
  • For tax reporting
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Our lawyers, auditors, and consultants
  • Other third parties as required by law

Compliance data

We collect this type of information from:

  • You
  • Third parties, including companies that help us conduct internal investigations.

Data elements in this category include:

  • Compliance program data, including records to demonstrate compliance with applicable laws, such as export control laws
  • Records relating to complaints and internal investigations, including compliance hotline reports

We use this type of information:

  • To comply with and demonstrate compliance with applicable laws
  • For legal matters, including litigation and regulatory matters, including for use in connection with civil, criminal, administrative, or arbitral proceedings, including in anticipation of litigation or enforcement of judgments and orders
  • For our Everyday Business Purposes

We may disclose this type of information to our Affiliates and Service Providers and to:

  • Our lawyers, auditors, consultants
  • Other third parties (including government agencies, courts and opposing law firms, consultants, process servers, and parties to litigation) in connection with legal matters

(1) Personal information about children under 16 cannot be sold without affirmative consent. We do not sell any personal information of children under 16.

(2) Everyday Business Purposes encompasses the Business Purposes (as defined in the CCPA) and the following related purposes for which personal information may be used:

  • To provide the information, product, or service requested by the individual or as reasonably expected given the context in which with the personal information was collected (such as customer credentialing, providing customer service, personalization and preference management, providing product updates, bug fixes, or recalls, and dispute resolution);
  • For identity and credential management, including identity verification and authentication, system and technology administration;
  • To protect the security and integrity of systems, networks, applications, and data, including detecting, analyzing, and resolving security threats, and collaborating with cybersecurity centers, consortia, and law enforcement about imminent threats;
  • For fraud detection and prevention;
  • For legal and regulatory compliance, including all uses and disclosures of personal information that are required by law or reasonably needed for compliance with company policies and procedures, such as anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines;
  • For corporate audit, analysis and reporting;
  • To enforce our contracts and to protect against injury, theft, legal liability, fraud or abuse;
  • To protect people or property, including physical security programs;
  • To de-identify the data or create aggregated datasets, such as for consolidated reporting, research, or analytics;
  • To make back-up copies for business continuity and disaster recovery purposes; and,
  • For corporate governance, including mergers, acquisitions, and divestitures.