Privacy Notice

Last Revised: September 30, 2020

This privacy notice (“Privacy Notice”) describes how Emerson Electric Co. and its subsidiaries and affiliates that link to this Privacy Notice – each entity data controller – (“Emerson,” “our,” “us” or “we”) may collect, use and share information relating to you as an identified or identifiable natural person (“Personal Data”).

Please read this entire privacy notice carefully before using our websites, email notifications, mobile applications, social media applications, widgets, and our other online services (the “Services”) because it will help you understand what data we collect, how we use and share it, and what your choices are with respect to that data.

About Us

Emerson Electric Co. (NYSE: EMR) is registered in the USA as a corporation in the State of Missouri and has its registered office at 8000 W. Florissant Avenue St. Louis, MO 63136, USA.

Contacting Us

If you want to exercise your data privacy rights as stated below or you have any questions about this Privacy Notice, our contact information is as follows:

The privacy representative of Emerson Electric Co. in the EEA can be contacted at:

Director of Data Protection – Europe

Email: [email protected]

Regular Mail: Argelsrieder Feld 3

Attention: Director of Data Protection

82234 Wessling, Germany

Telephone: +1.314.679.8984

Fax: +1.314.553.1232

For individuals outside the EEA:  

Email: [email protected]  

Regular Mail: Emerson Electric Co  

Attention: Website Inquiries 

8000 W. Florissant Avenue, Building AA,

St. Louis, MO 63136, USA

Telephone: +1.314.679.8984

Fax: +1.314.553.1232

You may also reach out to the respective Emerson affiliate – please click here for a list with contact details.

Overview

The Services of Emerson’s subsidiaries and affiliated companies are each owned, operated and provided by such subsidiaries and companies. Please click here for a list of Emerson's subsidiaries and affiliates. However, this Privacy Notice ONLY governs the use of Emerson company Services that specifically link to this Privacy Notice. Your use of certain products or services may be subject to additional privacy notices. Other Emerson company Services may link to or otherwise provide their own, separate notice.

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

Personal Data Collection

We may collect Personal Data from you through your use of the Services (especially, if you choose to provide it), including without limitation:

• Your name, email, username, phone number, company and address, (“Contact Information”);
• Your gender, age, citizenship, education, profession, occupation, and income level (“Demographic Information");
• Your credit card number, billing address, shipping address, security code and other payment transaction and verification details (“Payment Information”);
• Pages and products viewed, items added to your shopping cart, ads that you clicked on, emails from us that you opened, browser type, operating system ("OS"), Internet Protocol ("IP") address and device and location information (collectively, “Analytical Information”);
• Publicly available information about you from third-party sources, such as the postal service for shipping address verification;
• Your mobile OS, a mobile device identifier embedded by us, or other commonly used mobile device identifiers.

We may collect Personal Data from you about a third party.  For example, as part of our distributor account registration process, you may provide the name, phone number, and email of administrative and technical contacts.  If you submit any Personal Data about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Data in accordance with this Privacy Notice.

We may collect your Personal Information or usage data from third parties, including without limitation:

• Your email address and other collected Personal Data about you may be forwarded to Emerson by a third-party website when you request for Emerson to contact you through such third-party website;
• Your Personal Data may be forwarded to Emerson when you choose to participate in a third-party application or feature, such as live chat, one of our social media pages or a similar application or feature on a third-party website;
• Additional Personal Data may be forwarded to Emerson from third parties to combine with the Personal Data we collect through your use of the Services in order to enhance our ability to serve you, to focus content we provide to you and to offer you opportunities to purchase products or services that we believe may be of interest to you based upon the information we have collected.

We will apply the terms of our Privacy Notice to any Personal Data received from a third party, unless we have disclosed to you otherwise.  Emerson is not responsible for these third parties' dissemination of your Personal Data.

How We Use Your Personal Data 

We may use your Personal Data for the following purposes, as permitted by applicable law:

• Purchases: We may use your Contact Information and Payment Information to allow us to process and fulfill purchases you make through the Services.
• Customer Service: We may use your Contact Information to receive and respond to your questions about products, services or warranties and to communicate with you about contests, surveys or sweepstakes. To address your questions, we may also request your industry and/or the name and address of the dealer that sold you our product.
• Feedback: We may use your username, email address, products purchased, and other user-generated content you may provide when you rate and review our products.
• Website Registration: We may use your Contact Information and Demographic Information when you create an account through any of our Services in order to provide you a more personalized user experience.
• Analytics: When you use the Services, we automatically collect and use Analytical Information in order for us to continually improve your experience with our Services and to target marketing and advertising of our Products to you.
• Marketing: We may use your Personal Data to determine what products may be of interest to you, provide you with marketing communications (unless you have opted out of such communications) and to conduct market research. We may also use information you provide us, including your industry, whether you own our product, experience with our products, and user-generated content, for these marketing purposes.
• Location-Based Services: We may use your current location, provided address and/or zip code to provide you the location of the retailer of our products or other appropriate information.

We may also use your Personal Data in other ways that are consistent with the above-described purposes and to otherwise administer our websites and provide our Services to you.

Legal Bases for the Processing and Consequences

We rely on the following legal grounds for the collection, processing, and use of your Personal Data:

• the processing is necessary to provide the Services as requested by you;
• your consent;
• the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
• the processing is necessary for compliance with a legal obligation to which we are subject;
• the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except (for residents of the European Economic Area (“EEA”)) where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data; such legitimate interests are the fulfilment of the processing purposes set out above.

In general, the provision of your Personal Data is voluntary, but in certain cases it is necessary in order to enter into a contract with us or to receive our products or services as requested by you.

Not providing your Personal Data may result in disadvantages for you – for example, you may not be able to receive certain products and services. However, unless otherwise specified, not providing your Personal Data will not result in legal consequences for you.

Notice to Emerson Investors

Certain pages of our websites allow investors in Emerson to obtain publicly available information related to company performance. Investors may view and/or request certain information through our website here. Depending upon what information is requested by an investor, this feature of our website may ask for, and the investor may choose to provide, the investor’s name, title, organization, occupation, address, telephone number, and email address (“Investor Information”). Emerson will use Investor Information to verify an investor’s identity and fulfill any requests for information.

Notice to Employment Applicants

Certain pages of our websites include the ability for people interested in working for Emerson or one of its subsidiaries or companies to find out more information about employment opportunities at Emerson, its affiliates and/or subsidiaries. To apply for open positions using our website, you must create an employment profile through our website here, which includes the information that Emerson requests you to provide, and that you may choose to provide, to be considered for employment (the “Employment Applicant Information”).

Prior to creating an employment profile, you must affirmatively consent to the privacy terms governing the submission of your information to Emerson for employment purposes here. The terms that you agree to in order to create an employment profile shall govern Emerson’s use of the information you provide to apply for employment. Emerson will use Employment Applicant Information for evaluation and hiring purposes, and communication in furtherance of the evaluation and hiring purposes.

Security

We maintain appropriate technical and organizational measures to protect your Personal Data, including assuring that third-party service providers who access or handle Personal Data on our behalf and affiliates maintain such safeguards. We seek to encrypt credit card numbers from e-commerce transactions conducted on our websites using secure socket layer ("SSL") technology.

However, no method of Internet transmission or electronic storage is 100% secure or error-free, so it is not possible to guarantee absolute security. You must protect against unauthorized access to your password and to your computer, and be sure to sign off when finished using a shared computer. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please immediately notify us by email [email protected] or by calling us at +1.314.679.8984.

Where we have given you or you have chosen a password which enables you to access certain portions of our websites, you are responsible for keeping this password confidential. You should not share your password with anyone.

International Data Flow

The Personal Data that we collect or receive about you may be transferred to and/or processed by bodies that are located inside or outside the EEA.

Some of the recipients of your Personal Data (see also below) are located in countries with adequacy decisions (in particular, Canada (for non-public organizations subject to the Canadian Personal Data Protection and Electronic Documents Act) and Argentina), and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective (see Art. 45 General Data Protection Regulation – “GDPR”).

Other recipients might be located in countries which do not adduce an adequate level of protection from a European data protection law perspective (in particular, the USA).  We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority (Art. 46(2)(c) or (d) GDPR), approved codes of conduct together with binding and enforceable commitments of the recipient (Art. 46 (2)(e) GDPR), or approved certification mechanisms together with binding and enforceable commitments of the recipient (Art. 46 (2)(f) GDPR). You can ask for a copy of such appropriate safeguards by contacting us as stated above under the section Contacting Us.

Cookies

We use “cookies,” a small text file transferred to your device, along with similar technologies (e.g., internet tag technologies, web beacons and embedded scripts) to help provide you with a better, more personalized user experience. To learn more about how we use cookies and to change your cookie settings, please click here.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked.  Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.  
 

Google reCAPTCHA

We utilize Google reCAPTCHA, which is a free service that protects websites from spam and abuse using advanced risk analysis techniques to tell humans and bots apart. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google's Privacy Policy and Terms of Use.  More information as to Google reCAPTCHA and how it works is available here.

Personal Data Shared with Third Parties

We only share your Personal Data with companies, organizations and individuals outside of Emerson as described below.

• Recipients within Emerson and Third Parties. We may share your Personal Data with Emerson’s affiliates and other companies worldwide, including our unaffiliated dealers, manufacturers, and suppliers in order for these companies to contact you about their products, services or other offerings that may be of interest to you. We may also share your Personal Data with certain business partners. Depending on the categories of Personal Data and the purposes for which the Personal Data has been collected, different entities and the internal departments within these entities may receive your Personal Data. For example, our IT department may have access to your account data, and our marketing and sales departments may have access to your account data or data relating to product orders. Moreover, other departments within Emerson may have access to certain Personal Data about you on a need to know basis, such as the legal and compliance department, the finance department or internal auditing. This Privacy Notice does not govern unaffiliated third-party websites or any other website that does not link to this Privacy Notice.
• Service Providers. We may share your Personal Data with affiliated and unaffiliated companies that perform tasks on our behalf related to our business. Such tasks include processing payments, fulfilling orders, delivering packages, locational services, analyzing website or mobile application usage data, customer service, electronic and postal mail service, contests/surveys/sweepstakes administration, marketing services, social commerce and media services (e.g., ratings, reviews, forums), and calculating, managing and reporting sales tax. Third-party service providers receive your Personal Data as necessary to perform their role, and we instruct them not to use your Personal Data for any other purposes.
• As Required or Appropriate by Law. We will use and disclose your Personal Data as permitted by applicable law, including without limitation:
  • Under applicable law, including laws outside your country of residence, to comply with legal processes and to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • To enforce our terms and conditions, including investigations of potential violations thereof;
  • To detect, prevent or otherwise address fraud, security or technical issues; and
  • To protect our operations or those of any of our affiliates; to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.
• Business Transfers. As we continue to develop our business, we might sell or buy brands, stores, subsidiaries or business units. We may share and/or transfer your Personal Data with a third party in such transactions (including without limitation, any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets). Customer information generally is one of the transferred business assets, but remains subject to any preexisting applicable Privacy Notice.

We may share aggregated data that has been anonymized (so that you are not identified) with third parties – like publishers, advertisers or connected websites – and may make this data publicly available.  For example, we may share information publicly to show trends about the general use of our services or products.

Public Forums

Our websites may offer publicly accessible blogs, message boards, or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.

Links to Social Networking and other Third-Party Websites

Our Services may contain links to social networking and other websites and mobile applications that are operated and controlled by third parties. While we try to link only to websites that share our high standards and respect for privacy, we do not take responsibility for the content or the privacy practices employed by other websites. Unless otherwise stated, any Personal Data you provide to any such third party website will be collected by that party and not by us, and will be subject to that party’s privacy policy (if any), rather than this Privacy Notice. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the Personal Data you provide to them.

Children

In compliance with the Children's Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, our website does not permit children under 13 years of age to become users, and we do not intentionally collect information from children. By using our website, you represent that you are 13 years of age or older.

Your Choices and Rights

If you are located in, or residents of, certain geographic areas, you may have a number of rights in relation to your Personal Data, as described below.

South Africa Residents

Please see attached external privacy statement applicable to South Africa.

EEA Residents

In case you are located in the EEA when accessing the Services, or the data controller as further described above in the section Overview is located in the EEA, the following applies:

If you have declared your consent regarding certain collecting, processing and use of your Personal Data (in particular regarding the receipt of direct marketing communication via email, SMS/MMS, fax, and telephone – where applicable), you can withdraw this consent at any time with future effect. Further, you can object to the use of your Personal Data for the purposes of marketing.

Please note that the above-mentioned rights might be modified under the applicable data protection law. Below please find further information on your rights to the extent that the GDPR applies (for avoidance of doubt the following applies only in case you are located in the EEA when accessing the Services or the data controller as further described above in the section Overview is located in the EEA):

(i)    Right to request access to your Personal Data

You may have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. This access information includes the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipient to whom the Personal Data have been or will be disclosed.

You may have the right to obtain a copy of the Personal Data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

(ii)    Right to request rectification

You may have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

(iii)    Right to request erasure (right to be forgotten)

Under certain circumstances, you may have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data.

(iv)    Right to request restriction of processing

Under certain circumstances, you may have the right to obtain from us restriction of processing your Personal Data. In such case, the respective data will be marked and may only be processed by us for certain purposes.

(v)    Right to request data portability

Under certain circumstances, you may have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

(vi)    Right to object

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data. Such right to object may especially apply if Emerson collects and processes your Personal Data for profiling purposes in order to better understand your business interests in Emerson’s products and services. Further you may object to the use of your data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us. To exercise this right please contact us as stated above under the section Contacting Us.Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data. Such right to object may especially apply if Emerson collects and processes your Personal Data for profiling purposes in order to better understand your business interests in Emerson’s products and services. Further you may object to the use of your data for direct marketing purposes. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us. To exercise this right please contact us as stated above under the section Contacting Us.

However, such a right to object may in particular not exist if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

In case you have given us your consent for direct marketing purposes (e.g., you actively subscribed to our newsletters) you can withdraw your consent as described at the top of this section.

(vii)    Other rights in connection with automated decision-making

Furthermore, under certain circumstances with respect to automated individual decision-making, you have the right to obtain human intervention, express your point of view, and contest the decision.

You also may have the right to lodge a complaint with the competent data protection supervisory authority. You can execute this right at a supervisory authority in particular in the EEA Member State of your habitual residence, place of work or place of the alleged infringement.

How long we keep your data

Your Personal Data will be retained as long as necessary to provide you with the services and products requested. Once you have ended your relationship with us, we will either delete your Personal Data or anonymize your Personal Data, unless statutory retention requirements apply (such as for taxation purposes). We may retain your contact details and interests in our products or services for a longer period of time if you have allowed us to send you marketing materials. We may also retain your Personal Data after the termination of the contractual relationship if your Personal Data is necessary to comply with other applicable laws or if we need your Personal Data to establish, exercise or defend a legal claim, on a need to know basis only. To the extent possible, we will restrict the processing of your Personal Data for such limited purposes after the termination of the contractual relationship.

Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to:  [email protected].

California Residents

The California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”), requires that we provide California residents with a privacy notice that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information. For purposes of this California Residents section, we will refer to this information as “Personal Information.”

The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to Personal Information collected in a business-to-business context. That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occurs solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from, such entity.

(i)    Right to Know About Personal Information Collected, Disclosed, or Sold

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you. This right includes the right to request any or all of the following:

• Specific pieces of Personal Information that we have collected about you;
• Categories of Personal Information that we have collected about you;
• Categories of sources from which the Personal Information was collected;
• Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
• Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
• The business or commercial purpose for collecting or, if applicable, selling Personal Information.

        Collection of Personal Information

We currently collect and, in the 12 months prior to the “Last revised” date of this Privacy Notice, have collected the following categories of Personal Information about California residents directly from them and from data resellers, government entities, business partners and affiliated entities:

• Identifiers (name, postal address, internet protocol address, email address, account name)
• Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Telephone number
• Credit and debit card number
• Other financial information (e.g., household income, tax exempt number)
• Any information in the consumer’s application and claims history, including appeals records, if information is linked or reasonably linkable to consumer or household, including via device, by business or service provider
• Internet or other electronic network activity information (browsing history and information regarding consumer’s interaction with website, application or advertisement)
• Geolocation data
• Commercial information (records of personal property, products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies)
• Education information
• Professional or employment-related information
• Characteristics of protected classifications under California or federal law (e.g., gender and marital status)
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes 

In addition to the purposes stated above in the section How We Use Your Personal Data, we currently collect, and have collected and sold, the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device
• Advancing a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

          Disclosure or Sale of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose to service providers or sold to third parties in the 12 months preceding the " Last revised" date of this Privacy Notice and, for each category, the category of service providers or third parties to whom the Personal Information was sold or disclosed:

We do not knowingly collect or sell the Personal Information of minors under 16 years of age. 

(ii)    Right to Request Deletion of Personal Information 

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected. However, per the CCPA, we are not required to comply with a request to delete if it is necessary for us to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

(iii)       Right to Opt-Out of Sale of Personal Information

If you are a California resident, you have the right to direct us to stop selling your Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

To opt-out of our use of third-party advertising Cookies, please see the section Cookies above.  You may submit a request to opt-out of sales by clicking on this link: “Do Not Sell My Personal Information.” You also may submit a request by calling us at 1-888-905-0846.

If you would instead like to unsubscribe from our marketing communications, please select the unsubscribe link in the footer of our email communication or email us at [email protected]. 

(iv)      Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section California Residents. As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

How to Submit a Request to Know or Delete

You may submit a request to know or delete through our interactive webform available here or by calling us at 1-888-905-0846.

Our Process for Verifying a Request to Know or Delete

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure or deletion as applicable.

For requests to access categories of Personal Information and for requests to delete Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to access specific pieces of Personal Information or for requests to delete Personal Information that is sensitive and poses a risk of harm by unauthorized deletion, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities.  In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Authorized Agents

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above.  After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Shine the Light Law   

We may disclose personal information to third parties for them to directly market their products and services to you. If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the personal information disclosed during the preceding calendar year and the identity of the third parties. To make such a request, please send an email to [email protected] with the subject line “Shine the Light Request”.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities.  If you wish to access this Privacy Policy in an alternative format, please contact us as stated above under the section Contacting Us.

Changes

We may update this Privacy Notice from time to time. We will notify you of any such changes, including when they will take effect, by updating the “Last revised” date above or as otherwise required by applicable law.