California Privacy Policy

Effective Date: September 2023

Last Reviewed On: September 2023

This Privacy Notice for California Residents ("Notice") supplements the information contained in the Tech 21 Privacy Policy and applies solely to all visitors, users, and others who reside in the state of California ("consumers" or "you"). Tech 21 adopts this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) (as amended by the California Privacy Rights Act of 2020) and its implementing regulations. Any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.

This is an important notice regarding your privacy and the way in which Tech 21 UK Limited (referred to as “Tech 21”, “we”, “our” or “us” in this policy) collects and makes use of your personal data. We want to be open and transparent with you, and therefore encourage you to contact us if you have any questions about this policy or the ways in which we use your personal data.

This policy sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable privacy legislation, the data controller is Tech 21 UK Limited of Unit 6, Firmdale Village, Ryan Drive, Brentford, TW8 9ER, United Kingdom. Our company registration number is 05630013. Our ADEME unique identifier is FR279644_01TZWZ.

Questions regarding this policy should be directed to our Data Protection Compliance Manager. The Data Protection Compliance Manager is responsible for ensuring compliance with relevant data protection legislation and this policy and can be contacted by email at compliance@tech21.com. Any questions about the operation of this policy or any concerns that the policy has not been complied with should be referred in the first instance to the Data Protection Compliance Manager.

What information do we collect?

Tech 21 collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("Personal Information"). Personal Information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or other qualifying research data; or (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Tech 21 has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category	Examples	Collected
1. 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
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).	Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. “Personal information” does not include publicly available information that is lawfully made available to the public from federal, state, or local government records. Some Personal Information included in this category may overlap with other categories.	YES
3. Protected classification characteristics under California or federal law.	Age (40 years or older), race, colour, 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
4. Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
5. Biometric information.	Genetic, physiological, behavioural, 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
6. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
7. Geolocation data.	Physical location or movements, e.g., precise location data from GPS coordinates or telemetry data.	NO
8. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
9. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
10. 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
11. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.	YES

Sources from Which We Collect Your Personal Information

We obtain 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 on the Website.
Indirectly from you. For example, from observing your actions on the Website.
From third parties. For example, from someone you know ordering a product for you.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

To fulfil or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question 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 delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalise, and develop our website, products, and services.
To create, maintain, customise, 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 (with your consent, where required by law).
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.
To provide Website functionality to allow you to write a product review or submit a testimonial.
To operate contests, sweepstakes, and other promotions.

We 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.

Sharing Personal Information

We may disclose 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. In the preceding twelve (12) months, Tech 21 has disclosed Personal Information for a business purpose with the following categories of third parties:

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
1. Identifiers.	Service providers	None
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).	Service providers	None
3. Protected classification characteristics under California or federal law.	None	None
4. Commercial information.	Service providers Data analytic providers	None
5. Biometric information.	None	None
6. Internet or other similar network activity.	Service providers Internet service providers Data analytic providers	None
7. Geolocation data.	None	None
8. Sensory data.	Service providers Advertising networks	None
9. Professional or employment-related information.	None	None
10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	None	None
11. Inferences drawn from other Personal Information.	Service providers Data analytic providers Advertising networks	None

How Long Do We Retain Your Personal Information?

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Your Rights to Know and Delete below), 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 (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Right to Delete

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 (the "right to delete"). Once we receive and confirm your verifiable consumer request (see Exercising Your Rights to Know and Delete below), we will review your request to see if an exception allowing use to retain the information 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 products or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfil the terms of a written warranty or product recall conducted in accordance with federal law, 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.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).
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.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Correct My Personal Information:

You have the right to ask that we correct the personal information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law. To correct your personal information, click “Personal Information.”

Right to Limit the Use and Disclosure of SPI:

You have the right to ask that we limit our use and disclosure of your SPI to certain purposes permitted by law and can do so by clicking “Personal Information.”

Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either:

Submitting a request using our online form by clicking here. This should link customers through to the Personal Information page

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 only submit a request to know twice within a 12-month period. Your request to know or delete 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.

You do not need to create an account with us to submit a request to know or delete.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, (see Personal Information Sales Opt-Out and Opt-In Rights below).

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact compliance@tech21.com

We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing electronically.

We will securely deliver our written response electronically.

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 PDF or CSV format.

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.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers we know are less than 16 years of age unless we receive affirmative authorization (the "right to opt-in") from the parent or guardian of a consumer less than 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page: My Personal Information.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you products or services.
Charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of products or services.
Suggest that you may receive a different price or rate for products or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

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 use our online form by clicking here.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this 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 Tech 21 collects and uses your information described here your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Postal Address

Tech 21 UK Limited

ATTN: Privacy
Unit 6, Firmdale Village,Ryan Drive, Brentford, TW8 9ER
Email: compliance@tech21.com

If you need to access this Policy in an alternative format due to having a disability, please email us at compliance@tech21.com