California Consumer Privacy Act (supplements)

Win-Dor, Inc.

Last Revised on: December 23, 2022

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) applies only to information collected about consumers residing in California, Colorado, Virginia, Utah, or Connecticut (“consumer(s),” “Consumer(s),” “you,” “your”) and supplements the information contained our primary Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”) and any and all regulations arising therefrom.

This Supplemental Policy describes the practices of Win-Dor, Inc. and its subsidiaries (“Win-Dor,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests. Some portions of this Supplemental Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact Win-Dor at [email protected] or +1-866-457-2826 to access this Supplemental Policy in an alternative format.

Definitions Specific to this Policy

  • Consumer” means a natural person who resides in California, Colorado, Virginia, Utah and Connecticut and to whom we offer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.
  • Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below.
  • Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the Consumer, and 10) Health, sex life, or sexual orientation. Sensitive Personal Information includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
  • “Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.
  • “Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.
  • Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the CCPA, CPA, VCDPA, UCPA, and CDPA.
  • Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

These definitions apply, whether terms are capitalized or not. Other terms used in this Supplemental Policy may be defined under the CCPA, CPA, VCDPA, UCPA, or CDPA, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state. For example, if you are a Virginia consumer, terms defined in the VCDPA shall apply to you if they are used in this Supplemental Policy.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third parties with whom that category of personal information is shared. As this chart shows, we may share personal information to Third Parties or disclose certain personal information to Vendors for business purposes.

 

Category of Personal Information

(Length of Intended Retention)

 

Examples

 

Sources from Which This Personal Information is Collected

 

Business Purposes for Collection

 

Types of Vendors or Third Parties with Whom This Personal Information is Shared, Sold or Disclosed

Unique Identifiers

 

 

Real name, signature, alias, address, unique personal identifier, online identifier, IP address, email address, account name, social security number, physical characteristics or description ·  Websites

·  Web applications

·  In person and in writing including

o In home appointments

o Showrooms

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers,

·  Distributors,

·  Marketing agencies

·  Selling, marketing, installation, use, delivering and servicing of products

·  Facilitation of home automation services

·  Fulfillment of warranty obligations

Disclosed:

·  Distributors

·  Contractors and installers

·  Providers of home automation services and products

·  Website service providers

·  Financing institutions

·  Payment processors

·  Logistics providers

·  Marketing agencies

Shared or Sold:

·  Distributors

·  Contractors and installers

·  Providers of home automation services and products

Contact and Financial Information

 

Name, address, telephone, email, credit card number, debit card number, or any other financial information ·  In person and in writing including

·  In home appointments

o Showrooms,

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers

·  Distributors

·  Provide for financing arrangements and payment processing

·  Payments for products and services

Disclosed:

· Payment processors

· Financial Institutions

Shared or Sold:

None

Medical Information or Health Insurance Information

 

Injury information for workers compensation claim ·  In person and in writing including

·  In home appointments

o Showrooms,

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers

·  Distributors

·  Claims management Disclosed:

·  Distributors

·  Contractors and installers

Shared/sold:

· Distributors

· Contractors and installers

Characteristics of Protected Classifications

 

Age, gender, race, physical or mental health conditions, marital status

 

·  Web applications

·  In person and in writing including

o In home appointments

o Showrooms

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers,

·  Distributors,

·  Marketing agencies

 

·  Selling, marketing, installation, use, delivering and servicing of products

·  Fulfillment of warranty obligations

Disclosed:

·  Distributors

·  Contractors and installers

·  Website service providers

·  Logistics providers

·  Marketing agencies

Shared/sold:

·  Distributors

·  Contractors and installers

Commercial Information

 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies · Web applications

· In person and in writing including

· In home appointments

· Showrooms

· Trade shows

· Phone, email, including by call center and salespersons, surveys

· 3rd parties and service providers including contractors, installers,

· Distributors,

·  Selling, marketing, installation, use, delivering and servicing of products

·  Facilitation of home automation services

Disclosed:

·  Distributors

·  Contractors and installers

·  Providers of home automation services and products

·  Website service providers

·  Logistics providers

·  Marketing agencies

Shared or Sold:

·  Distributors

·  Contractors and installers

Internet or Other Electronic Activity

 

Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement · Websites

· Web applications

 

· To tailor marketing, selling, products and services offered

·To tailor and measure effectiveness of marketing investments and tracking of customer engagement

Disclosed:

None

Shared or Sold:

·  External marketing agency partners

·  Google Analytics and personalization platform entities

Geolocation Data

 

Device location ·  Websites

·  Web applications

·To provide local store information to customers

·To tailor marketing, selling, products and services offered

·To tailor and measure effectiveness of marketing investments and tracking of customer engagement

·Facilitation of home automation services

Disclosed:

None

Shared or Sold:

·  External marketing agency partners

·  Google analytics and personalization platforms

 

Audio, Electronic, Visual, Thermal, Olfactory, Or Similar Information

 

Call and video recordings · In person and in writing including

o  In home appointments

o  Showrooms

o  Trade shows

o  Phone, email, including by call center and salespersons, surveys

· 3rd parties and service providers including contractors, installers,

· Distributors

·  Selling, marketing, installation, use, delivering and servicing of products

·  Facilitation of home automation services

·  Fulfillment of warranty obligations

Disclosed:

·  Distributors

·  Contractors and installers

·  Providers of home automation services and products

·  Website service providers

·  Financing institutions

·  Payment processors

·  Logistics providers

·  Marketing agencies

Shared or Sold:

·  Distributors

·  Contractors and installers

·  Providers of home automation services and products

Inferences Drawn from Other Categories to Create a Profile

 

Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes · Websites

· Web applications

· In person and in writing including

o In home appointments

o Showrooms

o Trade shows

o Phone, email, including by call center and salespersons, surveys

· 3rd parties and service providers including contractors, installers,

· Distributors,

· Marketing agencies

·Selling, marketing, installation, use, delivering and servicing of products

·Facilitation of home automation services

 

Disclosed:

·  Distributors

·  Contractors and installers

·  Website service providers

·  Marketing agencies

Shared or Sold:

·  Distributors

·  Contractors and installers

 

Sensitive Personal Information We Collect and Disclose

 

Category of Sensitive Personal

Information

 

(Length of Intended Retention)

Sources

From Which This

Sensitive Personal

Information is Collected

Business

Purposes for Collection

Types of Vendors or Third Parties with Whom This Sensitive Personal Information is Shared, Sold or Disclosed
Social security, driver’s license, state identification card, or passport number

 

·  In person and in writing including

o  In home appointments

o  Showrooms

o  Trade shows

o  Phone, including by call center and salespersons

·   Provide to partners for financing Disclosed:

·  Financing institutions

Account log-in, financial account, debit card number, plus an access code

 

·  In person and in writing including

·  In home appointments

o Showrooms,

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers

·  Distributors

·  Provide for financing arrangements and payment processing

·  Payments for products and services

Disclosed:

· Payment processors

· Financial Institutions

Shared or Sold:

None

Precise Geolocation

 

 

Device location ·Websites

·Web applications

·Facilitation of home automation services

 

· To provide local store information to customers

· To tailor marketing, selling, products and services offered

· To tailor and measure effectiveness of marketing investments and tracking of customer engagement

Health Information

 

·  In person and in writing including

·  In home appointments

o Showrooms,

o Trade shows

o Phone, email, including by call center and salespersons, surveys

·  3rd parties and service providers including contractors, installers

·  Distributors

· Claims management

· Product Choice

Disclosed:

·  Distributors

·  Contractors and installers

Shared/sold:

· Distributors

· Contractors and installers

Retention of Data

We intend to retain each category of personal information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Your Rights to Your Personal Information

California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California consumers. Consumers in Colorado, Virginia, Utah, and Connecticut have similar rights and can find more detail by referencing the CPA, VCDPA, UCPA, or CDPA, as applicable.

You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request, or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:

  • The categories of personal information to be collected;
  • The purposes for which the categories of personal information are collected or used;
  • Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;
  • If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
  • The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by using the contact information provided below.

Right Know and Right to Access. You have the right to request certain information we have collected about you. You have the right to request:

  • Specific pieces and categories of personal information we collected about you;
  • The categories of sources from which personal information was collected;
  • The purposes for which personal information was collected, shared, sold, or processed;
  • The categories of personal information we shared, sold or disclosed; and
  • The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.

Right to Delete. You have the right to request that we delete certain personal information that we have collected.

Right to Correct. You have a right to request that we correct any inaccurate personal information we may retain about you.

Right to Opt-Out of the Sale and Sharing of Your Personal Information. You have the right to opt-out of the sale and sharing of your personal information with Third Parties, and the right to opt-out of the processing of personal information for targeted advertising purposes, as defined in the CCPA, CPA, VCDPA, UCPA, and CDPA.

SHARE/PROCESS PERSONAL INFORMATION: We share personal information, or process personal information for targeted advertising purposes. In the past 12 months, we have shared the categories of consumer personal information as listed in this Supplemental Policy. As a consumer, you have the right to opt-out of the sharing of your personal information and of the processing of personal information for the purpose of targeted advertising. To submit an opt-out request, please access the below link or follow the “Instructions to Exercise Your Rights,” below. We do not knowingly sell or share personal information of consumers under 16 years of age.

Update Contact Preferences | Win-Dor: “Do Not Share My Personal Information.

If you opt-out of the sharing of your personal information, we will wait at least 12 months before asking you if we may share your personal information.

You have the right to opt-in to the sale of your personal information after you have opted out. If you would like to opt-in to the sale or sharing of your personal information, please email us at [email protected] or call us at 1- +1-866-457-2826. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

Right to Consent to or Limit the Use of Your Sensitive Personal Information. You have the right to consent to the use of your Sensitive Personal Information in CO, CT, VA and UT.  Separately, you have the right in CA to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average consumer or for specific business purposes defined by law.

USE SENSITIVE PERSONAL INFORMATION OTHER THAN AS LISTED IN THE CCPA: We use Sensitive Personal Information with your consent, and for the purposes listed in Section D. In CA, you have the right to further limit the use of your Sensitive Personal Information to the purposes authorized by the CCPA. To submit a request to limit the use of your Sensitive Personal Information, please access the below link.

Right to Non-discrimination. You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click here or call us at , or +1-866-457-2826. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at [email protected].

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

Right to Appeal for California, Virginia, Colorado, and Connecticut Consumers. You have the right to appeal our decisions about your data subject requests. If you choose to appeal, your request will move from Operations to our Legal Department for review.  If you would like to appeal a decision regarding your data request, please click here or call 1-+1-866-457-2826.  Please state that your request is an “Appeal,” and describe the date and nature of your original request.

Verification Process

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

  • Verify your identity with us directly.
  • Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

Personal Information of Minors

Our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years, except as required by applicable law. If you believe that a child has submitted personal information to us, please contact us at [email protected], or call us at +1-866-457-2826 and we will delete the information.

Additional California Privacy Rights

Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”

Financial Incentives for California Consumers/Contractors. Under California law, we may provide financial incentives to California Business to Business contractors (defined as Product Dealers, Installers, and Service Professionals) who allow us to collect, retain, or share personal information collected from Consumers on Win-Dor’s behalf. These contractors may receive incentives that may include monetary payments, program rewards, and/or a higher level of goods or services.

Changes to Our Supplemental Policy

Win-Dor reserves the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post an updated policy on our website with the effective date.

Additional Information

If you would like additional information regarding our Supplemental Policy, please contact us at [email protected] or +1-866-457-2826.

Win-Dor, Inc.
450 Delta Avenue
Brea, CA 92821

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