C.R.
LAURENCE PRIVACY POLICY
Updated December 20, 2019
At C.R.
Laurence Co., Inc., a CRH Company (“CRL”, also referred to as "us" or
"we" in this Privacy Policy), your personal privacy is important to
us. The following Privacy Policy describes the practices that we have adopted.
Please review this Privacy
Policy, which governs the information collected through use by you (collectively
sometimes referred to herein as "you" or "your") of the
Website, or information collected in any other manner. Each time you access, use, or browse the
Website, you signify your acceptance of the then-current Privacy Policy. If at any time you do not accept this Privacy
Policy, then you are not authorized to access, browse or use the Website and
you must discontinue use of the Website immediately.
Our Collection and Use of Your
Personally Identifiable Information
As part of the normal operation of the
Website, we may collect and, in some cases, use or disclose personally
identifiable information (referred to herein as “personally identifiable
information” or "PII") about you where we reasonably believe it will
help us administer our business or provide products, services or other
opportunities to you as described below.
For your convenience, we are
listing the categories of PII that we collect below and have collected within
the past 12 months:
|
Category
|
What
We May Collect |
How
Collected |
Reason
for Collection* |
|
|
A real name,
alias, postal address, unique personal identifier, Internet Protocol address,
online identifier, email address, account name, Social Security number. |
Through the Website,
In-Person, Written in a completed form, application or other written
correspondence, Web Chat and/or By Telephone. |
To market a service or
product to you or complete a transaction for you; marketing and promotional
efforts, statistically analyze Website usage, improve Website content and product
offerings and customize Website content, layout and services. |
|
|
A name,
signature, Social Security number, address, telephone number, bank account
number, credit card number, debit card number, or any other financial information.
|
Through the Website,
In-Person, Written in a completed form, application or other written
correspondence, Web Chat and/or By Telephone. |
To market a service or
product to you or complete a transaction for you; marketing and promotional
efforts, statistically analyze Website usage, improve Website content and
product offerings and customize Website content, layout and services. |
*In addition to the reasons
for collection described above, we may, in our sole discretion, retain original
and updated PII as part of our records for reasons such as technical
constraints, dispute resolution, trouble-shooting and
agreement enforcement.
In addition to PII, we may
also collect, aggregate, and share "Non-PII" which is information
that is aggregated, anonymized, de-identified and is unable to be readily
identified to you.
This Privacy Policy only
addresses the use and disclosure of PII and other information we may collect
from you. We do not have a process for
you to request changes to your personally identifiable information that is
collected in any manner.
CRL collects information from our users at
several different points, including but not limited to the following:
Personally Identifiable Information You Provide To Us
Any personal information that we may collect
about you is voluntarily provided to us by you.
We receive and may store the information you provide to us. As you navigate through the Website, there
are several online forms which you can use to request information about
us. In order for us to respond to your
request, we ask that you provide to us, among other things, your first and last
name, mailing address, telephone number, and email address on the online form.
Other information may be identified as optional, and you may choose whether or
not to provide it. The use of these
online forms is completely voluntary. We
may use your first and last name, email address, mailing address and telephone
number to contact you from time to time.
In addition, we may use that information internally for assessing our
business and how the Website is used. Visitors to the Website may navigate the
entire Website without using any of these features or providing any
information.
Correspondence
If you correspond with us, we may retain such
information and PII included as part of the correspondence. In addition, where
we have sent an email to you, we may receive confirmation that you have opened
it. If you want to unsubscribe from a CRL
email list, please let us know by following the “Unsubscribe” instructions that
are included in each promotional email from us.
Please note that such requests may take up to ten (10) days to become
effective.
Cookies
and Other Tracking Methods
Like many websites, we use cookies and similar technologies to collect
additional website usage data. A cookie
is a small piece of text sent to your browser by a website you visit. It helps
the website to remember information about your visit, like your preferred
language and other settings. That can make your next visit easier and the site
more useful to you. Cookies do not
contain personally identifiable information; however, once you choose to
furnish a site with personally identifiable information, this information may
be linked to the data stored in the cookie.
When
you access our Website, we look into the cookie to fill out some fields you
would otherwise have to re-enter (but not passwords or any financial information)
and customize our Website to be more relevant to you. There are products
commercially available that are designed to help you disable cookies. You may delete and/or decline our cookies by
selecting the appropriate settings on your browser, but some parts of our
Website may not work properly if you do so and this may affect your ability to
use the full functionality of the Website.
Also, most browsers have incorporated certain “do not track” (DNT)
features. Most of these features, when
turned on, send a signal or preference to the website that a user visits,
indicating that the user does not wish to be tracked. At this time, our Website does not respond to
browser “do not track” (DNT) signals or other “opt out” settings or features
that may be offered by your browser or similar devices, however, we reserve the
right to do so in the future.
Google
Analytics
Our Website uses Google Analytics, a web analytics service provided by Google.
Google Analytics uses cookies and similar technologies to collect and store
anonymous information about you, which may include the non-personal information
described above. You can read information about how Google Analytics may use
your data at http://www.google.com/policies/privacy/partners/, Google’s
Privacy Policy at http://www.google.com/intl/en/policies/privacy/, and
Google Analytics Terms of Use at http://www.google.com/analytics/terms/us.html.
Our Website may use certain features of Google Analytics, including:
(a) “Demographics and
Interest Reporting” to analyze information regarding the interests and
demographics of users of the Website. We
use such non-personal information in the same manner as we use other
non-personal information as described in this Privacy Policy.
(b) “Remarketing with
Google Analytics” to place ads on other sites directed to people who have
visited the Website.
(c) “Google Display
Network Impression Reporting” to report how people’s interactions with our ads
relate to their visits to the Website.
You can opt-out of Google
Analytics for Display Advertising and customize Google Display Network ads by
changing the ad settings at https://support.google.com/ads/answer/2662856. You also can opt-out from being tracked by
Google Analytics in the future by downloading and installing Google Analytics
Opt-out Browser Add-on for your current web browser at https://tools.google.com/dlpage/gaoptout/.
Surveys
From
time-to-time, our Website may request information from you via surveys.
Participation in these surveys or contests is completely voluntary and you may
choose whether or not to disclose this information. PII and other information
requested may include, but is not limited to, contact information (such as
name, telephone number, email and mailing address).
Personally Identifiable Information and Information from Other Sources
We may
receive PII and information about you from other sources, such as our agents,
vendors and service providers and from publicly available sources. For example,
sometimes we receive updated address information from third parties that we may
use to update our records.
Disclosing Personally Identifiable Information To Third Parties
We do not sell or rent your personally identifiable information. We may, however, share your PII with third
parties (including any agents, vendors, service providers and any affiliate or
subsidiary we may have) ,under the following circumstances:
(1) The PII is provided to
help promote or otherwise market a service or product to you or complete a
transaction for you.
(2) The PII is provided to
our agents, vendors or service providers who perform functions on our behalf. These
agents, vendors or service providers only receive PII, if such information is
needed to perform their function(s) or services, and they are not authorized to
use any PII for any purpose(s) other than the purpose(s) set forth by us.
(3) The PII is provided to
comply with applicable law, regulation or governmental request, enforce our
Terms of Use or other agreements we have with you, or to protect our rights,
property or safety, or the rights, property or safety of our users or others.
(4) The disclosure of PII is
done as part of a purchase, sale or transfer of services or assets (for
example, if substantially all of our assets are acquired by another party, your
PII may be one of the transferred assets).
We may also transfer such PII in the course of corporate divestitures,
mergers, dissolution, joint ventures or reorganization.
We may store PII in
locations outside our direct control (for instance, on servers or databases
co-located with hosting providers).
For your convenience, you may
consult the chart below to see what information we disclose and what categories
of information we have disclosed in the prior 12 months.
|
Category
|
What
We May Disclose |
To
Whom PII is Disclosed |
Reason
for Disclosure* |
|
Identifiers.
|
A real name,
alias, postal address, unique personal identifier, Internet Protocol address,
online identifier, email address, account name, Social Security number. |
Our employees and third
parties including any agents, vendors, service providers and any affiliate or
subsidiary we may have. |
To market a service or
product to you or complete a transaction for you; or for agents, vendors or
service providers who perform functions on our behalf |
|
Personal
information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e)).
|
A name,
signature, Social Security number, address, telephone number, credit card
number, debit card number, bank account numbers or any other financial
information. |
Our employees and third
parties including any agents, vendors, service providers and any affiliate or
subsidiary we may have. |
To market a service or
product to you or complete a transaction for you; or for agents, vendors or
service providers who perform functions on our behalf. |
*In addition to the reasons
for disclosure described above, we may, in our sole discretion, disclose
original and updated PII to comply with applicable law, regulation or
governmental request, to enforce our Terms of Use or other agreements we have
with you, or to protect our rights, property or safety, or the rights, property
or safety of our users or others.
We may also gather
aggregated data about you and disclose the results of such aggregated
information (but not PII) to third parties for marketing, promotional or other
purposes.
Sale
of Personally Identifiable Information
In the preceding twelve (12) months, we have not sold personally
identifiable information.
Inapplicability
of Privacy Policies of Any Linked Websites or Other Third Parties
Our
Website contains links to or integrations with other sites, whose information
practices may be different than ours. Visitors should consult the other sites'
privacy notices as we have no control over information that is submitted to, or
collected by, these third parties.
This
Privacy Policy only addresses CRL’s use and disclosure of your personally
identifiable information. We are not responsible for the privacy practices of
any third parties or the content of linked websites, although we encourage you
to read any applicable privacy policies of such parties or websites.
Protection
of Personally Identifiable Information
We have put in place appropriate physical, electronic and managerial procedures
to safeguard against foreseeable risks, such as unauthorized access. Please be aware that the Website and data
storage are run on software, hardware and networks, any component of which may,
from time to time, require maintenance or experience problems or breaches of
security beyond our control. We are not
responsible for the acts and omissions of any third parties.
No transmission of data
over the internet is guaranteed to be completely secure. We cannot guarantee the security of the
information on and sent from the Website. It may be possible for third parties
not under our control to intercept or access transmissions or private
communications unlawfully. While we strive to protect your personally
identifiable information, we cannot ensure or warrant the security of any
information you transmit to us over the internet. Any such transmission is done
at your own risk.
Compromise of Personally Identifiable Information
In the event that PII is
compromised as a result of a breach of security, we will promptly notify those
persons whose PII has been compromised, in accordance with applicable law.
Information
from Children
Because of
the nature of our business, our products and services are directed to persons
18 years of age or older and are not designed to appeal to minors. If you provide information to us through the
Website, you represent and warrant to us that you are 18 years of age or
older. We do not knowingly attempt to
solicit or receive any information from children. Specifically, the Website is
not intended or designed to attract children under the age of 13. If you are 13 -17 years of age, you may
visit, browse and use the information on the Website, but you may not submit
any personal information to the Website, and you represent and warrant that you
have permission of your parent or guardian to use the Website, who agrees to
this Privacy Policy and the Terms of Use on your behalf. If you are a parent and believe that we may
have inadvertently collected personal information from your child, please
notify us immediately by sending an email, including the Website to which your
request pertains, to CRLPrivacy@crlaurence.com.
Conditions
of Use, Notices and Changes to Our Privacy Policy
By using
the Website you agree to the terms and conditions in this Privacy Policy and
the CRL Terms of Use (the terms and conditions of which are hereby incorporated
by reference). In the event of any conflict between the terms and conditions of
this Privacy Policy and the Terms of Use, then the Terms of Use shall control.
If you do not agree to any of these terms and conditions you should not access,
browse or use the Website.
You agree
that any dispute over privacy or the terms contained in this Privacy Policy,
our Terms of Use, or any other agreement we have with you will be governed by
the law of the State of Georgia.
As our
business changes from time to time, this Privacy Policy and the Terms of Use
are subject to change at any time. We
reserve the right to amend the Privacy Policy and Terms of Use at any time, for
any reason, without notice to you, other than the posting of the amended
Privacy Policy and/or Terms of Use to the Website and changing the version
number and date of the Terms of Use and Privacy Policy which is noted just
below the first line of text that is the title of these documents. . The use of
your information is subject to the Privacy Policy and Terms of Use in effect at
the most recent time of use. The policies and procedures described herein
replace all previous policies and procedures regarding this subject. We
encourage you to periodically check back and review the policies and procedures
so that you always will know what PII and other information we collect, how we
use it, and with whom we share it.
Governing
Law
This Privacy Policy shall be governed by, and will be construed under, the laws
of the State of Georgia, U.S.A., without regard to choice
of law principles. Those who choose to access the Website from locations
outside of the United States do so on their own initiative, and are responsible
for compliance with local laws if and to the extent local laws are applicable,
including without limitation, all applicable laws, rules and regulations
regarding the transmission of data exported from the United States or the
country in which you reside.
Notice
of Privacy Rights of California Residents
Personal Information
Shared for Direct Marketing Purposes
If you are a California
resident and have provided personal information to us, you are entitled by law
to request certain information about the personal information we shared, if
any, with other businesses for their own direct marketing uses. To make such a
request, send an email to CRLPrivacy@crlaurence.com with "Request
for California Privacy Information" on the subject line and in the body of
your message. Include the website or
line of business to which your request pertains. We will provide the requested information to
you at your e-mail address in response. Please allow thirty (30) days for a
response. We are required to respond to
only one request per customer each year, and we are not required to respond to
requests made by means other than through the above email address.
We will not share your
personal information with third parties for their direct marketing purposes if
you request that we do not do so. You
may make such a request by sending us an email at CRLPrivacy@crlaurence.com
or mailing your request to CR
Laurence, 2503 E. Vernon Avenue, Los Angeles, CA 90058, Attention: Privacy
Officer. When
contacting us, please indicate your name, address, email address, which website
or line of business to which your request pertains, and what personal
information you do not want us to share with third parties for their direct
marketing purposes. Please note that there is no charge for controlling the
sharing of your personal information or for processing this request.
California Do Not Track
Disclosures
California Business &
Professions Code Section 22575(b) (as amended effective January 1, 2014)
provides that California residents are entitled to know how a website operator
responds to “Do Not Track” (DNT) browser settings. DNT is a feature offered by some browsers which,
when enabled, sends a signal to websites to request that your browsing is not
tracked, such as by third party ad networks, social networks and analytic
companies. We do not currently take
actions to respond to DNT signals because a uniform technological standard has
not yet been developed. We continue to
review new technologies and may adopt a DNT standard once one is created. For information about DNT, please visit: www.allaboutdnt.org.
California Residents: Your
Request Rights
This privacy notice for
California residents supplements the information contained in the previous
portions of this Privacy Policy and applies solely to all visitors, users, and
others who reside in the State of California ("consumers" or
"you"). We adopt this notice
to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as may be
amended or supplemented, and any terms defined in the CCPA have the same
meaning when used in this notice.
If you are a California
resident, you should be aware that you have certain special rights regarding
your PII and any “personal information” as that term is described in the California
Consumer Privacy Act. Such information is collectively referred to in this
Privacy Policy as “personal information”.
1) If you are a California
resident, you may request that we disclose the following:
(a) The categories of personal information we have collected about you.
(b) The categories of sources from which the personal information is
collected.
(c) The business or commercial purpose for collecting or selling
personal information.
(d) The categories of third parties with whom we share personal
information.
(e) The specific pieces of personal information we have collected about
you.
2) If you are a California
resident, we are obligated to make additional disclosures if we choose to sell
or share your data for business purposes.
While we do not sell your personal information, we may disclose your
personal information to third parties in the ordinary course of business. Following this, we will disclose the
following at your request:
(a) The categories of personal information that the business collected
about you.
(b) The categories of personal information that the business sold about
you and the categories of third parties to whom the personal information was
sold, by category or categories of personal information for each third party to
whom the personal information was sold.
(c) The categories of personal information that we have disclosed about
you for a business purpose.
You may request the above
information at least twice per 12 month period. We will ask for some verification to comply
with this request in order to protect your privacy.
3) If you are a California
resident, you may also make a request to delete the information we have
collected about you.
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.
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, 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:
(1) Sales, identifying the personal
information categories that each category of recipient purchased; and
(2) 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:
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
You have the right to direct
us to not sell your personal information at any time (the "right to
opt-out"). 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 link:
Do Not Sell 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.
However, you may change your mind and opt back in to
personal information sales at any time by e-mailing us at CRLPrivacy@crlaurence.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.
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 filling out the form HERE or by contacting us at CRLPrivacy@crlaurence.com or calling us at 1-800-390-1311
describing your request(s). The
verification we may request will reflect personal information that you have
previously provided to us.
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. These requests are
free, though we reserve the right to implement a reasonable fee for excessive
or complex requests you may submit. 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 90 days), we
will inform you of the reason and extension period in writing.
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.
Personal Information Sales Opt-Out and Opt-In
Rights
If you are 16 years of age
or older, you have the right to opt-out and direct us to not sell your personal
information at any time. We do not sell
the personal information of consumers we actually know are less than 16 years
of age, unless we receive affirmative authorization (the "right to
opt-in") from either the consumer who is between 13 and 16 years of age,
or the parent or guardian of a consumer less than 13 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 link:
Do Not Sell 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. However, you
may change your mind and opt back in to personal
information sales at any time by e-mailing us at CRLPrivacy@crlaurence.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.
Questions
Regarding This Privacy Policy
If you
have any questions about our Privacy Policy, please contact us at CRLPrivacy@crlaurence.com or you can write to us at CR Laurence, 2503 E. Vernon Avenue, Los Angeles, CA 90058, Attention:
Privacy Officer.