Crown Laboratories’ Privacy Notice for California Consumers

Effective Date: January 1, 2020

Crown Laboratories, and its United States related, affiliated, or subsidiary companies, (collectively “Crown,” “we,” “us,” or “our”) provides this Privacy Notice for California

Consumers (the “CCPA Privacy Notice”) to supplement the information contained in Crown’s Privacy Policy .The CCPA privacy Notice applies only to visitors, users, and others who are Consumers residing in the State of California from whom we collect personal information, however collected (“Consumers” or “you”). This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We may collect information from you in a variety of different situations, including, but not limited to on our Website, your mobile device, through email, in stores, through the mail, and/or over the telephone, 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”). More specifically, Crown has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category

Examples of Personal Information Collected

Channel

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.

Website/Mobile Device/In Store/email/
mail/telephone

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

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.

Website/Mobile Device/In Store/email/
mail/telephone

C.Commercial information.

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

Website/Mobile Device/In Store/email/
mail/telephone

D. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Website/Mobile Device/In Store/email/
mail/telephone

E. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Website/Mobile Device/In Store/email/
mail/telephone

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

Crown obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.

How We Use Personal Information

We may use, share or disclose the personal information we collect from you or about you with our Service Providers with whom we have a written contract, under circumstances that do not constitute a sale by virtue of contract language which meets the specific requirements of the CCPA, for one or more of the following business purposes:

To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to ask us a question or inquire about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate any applicable delivery.When you order products and services, we may also save your information to facilitate new product orders or process returns.
To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
To inform you about products and services you have purchased from us such as product recalls and warranty information.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For research, analysis, and business development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Crown assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Crown about our Consumers is among the assets transferred.

Crown 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.

How We Share Personal Information

Crown may disclose or share your personal information to a third party for a business purpose When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Service providers.
Third parties with whom you direct us to share your personal information

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Commercial information.
Category D: Internet or other similar network activity.
Category E: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers
Data aggregators, such as analytical services for business performance and measurements

Your Consumer Rights and Choices

The CCPA provides Consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Crown disclose our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 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 (also called a data portability request).
If we disclosed your personal information for a business purpose, a list containing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

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

In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, 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.
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.
We could not verify your identity, or we have determined that you are not entitled to exercise the right you are attempting to exercise because you are not a “consumer” as that term is defined under the CCPA.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at 1-800-877-8869.
Emailing us at CCPA@crownlaboratories.com

Only you, or a person registered with the California Secretary of State that you authorize 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 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.

Making a verifiable consumer request does not require you to create an account with us.

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

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 (up to [45/90] days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability 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, specifically Excel.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

However, we may offer you different price, rate, level, or quality of goods or services in connection with our Crown Rewards Program, which does not constitute discrimination under CCPA.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to ccpa@crownlaboratories.com.

Changes to Our CCPA Privacy Notice

Crown 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 above. Your continued use of our Website or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Privacy Notice constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Crown collects and uses your information described above and in the Privacy Policy 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: 800-877-8869

Email: CCPA@crownlaboratories.com

Postal Address:
Crown Laboratories, Inc.
Customer Service
207 Mockingbird Lane
Johnson City, TN 37604