Your California Privacy Rights

Your California Privacy Rights
Version 1.0
Last Revised: July 21, 2020

At M.M.LaFleur, we appreciate the trust you place in us when you choose to visit our stores and use our websites and mobile applications, and we take that responsibility seriously. This California Privacy Rights Notice (the “Notice”) supplements the M.M.LaFleur Privacy Policy by describing your privacy rights if you are a California resident (“you”) and including information on how to submit a request to exercise your rights. It also describes our current practices for each of the topics addressed in the Notice, as well as our practices regarding personal information collected, used, disclosed, or “sold” as of the effective date of this Notice.

California law defines “personal information” broadly as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

This Notice also uses that definition for personal information.

Categories of Personal Information We Collect
Please refer to the “Information We Collect” section in our Privacy Policy to understand the categories of personal information we may have collected about you. Please see the “Information We Collect” section in our Privacy Policy also sets forth the sources from which we get personal information.

Purposes for Which We Use Personal Information
Please refer to the “Use of Your Personal Information” section in our Privacy Policy to understand the purposes for which personal information is used.

Categories of Personal Information We Have Disclosed for a Business Purpose
We share personal information about you with service providers and third parties for business purposes, such as operational purposes and other purposes related to providing you with the products and services you seek from us. We provide more information about the business purposes for which we disclose personal information in the “Disclosure of Your Personal Information” and “Onward Transfer” sections of our Privacy Policy. We may share any of the categories of personal information listed in the “Information We Collect” section of our Privacy Policy for business purposes.

Categories of Personal Information We Have “Sold”
We do not provide personal information about you to other companies for money. We do share personal information with companies that we work with, including to help us market or advertise to you. When this information is in a format that directly identifies you by name, it is generally not shared with any companies for third-party marketing or advertising purposes. You can find more detail about our practices in our Privacy Policy, including in the “Disclosure of Your Personal Information” and “Onward Transfer” sections. Even though we do not provide personal information to these companies for money, California law may characterize our providing the following categories of information we share with companies that provide services to you or to us, such as personalizing your experience with us or helping us to market or advertise our products and services to you, as “sales” of personal information:

  • • Device and browsing information and other Internet activity information
  • • Purchase or other commercial information
  • • Demographic information
  • • Identifiers and contact information
  • • Inferences

Please see the “Information We Collect” section of our Privacy Policy for further information about what these categories of personal information include. See the “Submitting a Request” section below to request to opt out. M.M.LaFleur does not knowingly “sell” the personal information of minors under 13 years of age.

Important Note For California Residents Regarding Use by Facebook of Your M.M.LaFleur-related Data:

Facebook has adopted the policy – unless we tell them otherwise and elect to disable the feature – that as a default between July 1, 2020 and July 31, 2020 and thereafter if we elect it will treat all California residents as having elected to “opt-out” of what the CCPA considers to be “sales” of their data to advertising platforms like Facebook. That means Facebook would not use data we have collected about you in tracking your use of the web – for example, your visits to the M.M.LaFleur site and purchases you have made while there – to deliver M.M.LaFleur advertisements to you while you’re on the Facebook site. We have instructed Facebook to disable this feature for M.M.LaFleur such that going forward Facebook will not automatically make the assumption you have elected to opt-out of “sales” by us of your M.M.LaFleur-related data to platforms like Facebook. Rather, we will only cease “sales” of your data, and so “flag” such data for Facebook and other platforms so that they are aware of your election and act accordingly, if you elect to opt-out of such sales per the opt-out instructions below.

Access to Specific Information and Data Portability Rights
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. 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 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.

Deletion Request Rights
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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. 1. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. 3. Debug products to identify and repair errors that impair existing intended functionality.
  4. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 6. 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.
  7. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. 8. Comply with a legal obligation.
  9. 9. Make other internal and lawful uses of that information that are compatible
    with the context in which you provided it.

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:

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 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.

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

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 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.

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 actually know are less than 16 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing dataprivacy@mmlafleur.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at dataprivacy@mmlafleur.com.

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

Updates to This Notice
We may make changes to this Notice, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Notice, we will notify you by posting the updated Notice on our website, and we will update the effective date at the end of this Notice.

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 we collect and uses your information described here 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:

Privacy Hotline: 1-888-377-5524
Email: dataprivacy@mmlafleur.com
Postal Address:
M.M.LaFleur, Inc.
Attn: Customer Experience Team
100 Broadway Fl. 3
New York, NY 10005

This Notice is effective July 21, 2020.