Privacy Notice for California Residents

Effective Date 1st June 2024

This Privacy Notice for California Residents (this “Privacy Notice”) is intended to supplement Prinova’s Privacy Policy and applies only to California residents. Any terms defined in the Prinova Privacy Policy have the same meaning when used in this Privacy Notice.

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, (collectively, the “CPRA”) and other California privacy laws, California residents have the right to be informed about the data we collect about them. This Privacy Notice applies solely to natural persons who are California residents, as defined in the CPRA. Please note that this notice does not apply to residents of California who are acting as employees or job applicants. Any terms defined in the CPRA have the same meaning when used in this Privacy Notice.

The CPRA defines “Personal Information” 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 consumer or household.” Personal Information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the VCDPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other relevant federal and state laws, or clinical trial data; and
• Personal information covered by certain federal and state sector-specific privacy laws, including but not limited to, the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), and the Driver’s Privacy Protection Act of 1994.

Below are the categories of Personal Information that we may have collected, used, and disclosed for a business purpose, as permitted by law, in the last twelve (12) months, depending on the products or services you receive:

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;
• The internet sites of Prinova and its affiliates that you visit;
• The mobile applications of Prinova and its affiliates that you use;
• You or your employer, such as via telephone, mail, email, or at trade shows, or in connection with potential employment or business opportunities;
• Our customers, vendors, and suppliers;
• Third parties from whom we purchase contact data, such as LinkedIn.

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or 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, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including todevelop and improve our website, products, and services.
• For employment-related matters including, but not limited to, employee onboarding, payroll, and employee benefits.
• 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 CPRA.

We may share certain of your Personal Information with a third party for business purposes. When we share 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, Prinova has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category C: Personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

We share your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers (including, but not limited to, carriers and other logistics subcontractors, attorneys, accountants, IT service providers, payroll processors, and benefits providers).
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

In the preceding twelve (12) months, Prinova had not sold any of your Personal Information.

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

Right to Know/Access Personal Information

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:
  • 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 Deletion of Personal Information

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:

• 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.
• 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.

Right to Correct Inaccurate Personal Information

You have the right to request Prinova to correct inaccurate Personal Information collected about you. Prinova will make commercially reasonable efforts to correct any inaccurate Personal Information we hold about a consumer within 45 days of receiving a verifiable consumer request. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Right to Opt-Out of Personal Information Sales and Sharing

If you are age 16 or older, you have the right to direct us to not sell or share your Personal Information for cross-context behavioral advertising purposes at any time (the "right to opt-out"). Please note that we do not currently engage in sales of Personal Information but do share Personal Information with service providers. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

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 writing to us to specifically ask to opt in to such sharing of Personal Information with third parties.

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.  Please note that if we are not able to share some Personal Information with service providers, we may not be able to complete the services for which you have engaged us.

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. To designate an authorized agent, we must have received a written verifiable request from you designating that agent by name. Such a request may be sent by email.

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, which may include:
  • Your name, address, and any other information we may require verifying your identity.
  • 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. However, we do consider requests made through any password protected account you have with us sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will confirm receipt of your request within 10 business days. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and the extension period in writing.

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.

We will not discriminate or retaliate against you for exercising your consumer rights under the CPRA, including denying you goods or services. We may, however, offer a different price, rate, level, or quality of goods or services if that price or difference is reasonably related to the value provided to us by your data.

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. We do not provide such information for third parties for that purpose, however, to make such a request, please send an email to privacy@prinovaglobal.com.

We reserve the right to amend this Policy Notice at our discretion and at any time. When we make changes to this Policy Notice, we will post the updated notice on our website and update the Policy Notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this Policy Notice, the ways in which we collect and use 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:

Phone:  +1 (630) 868-0300

Website:  https://prinovaglobal.com

Email: privacy@prinovaglobal.com

Address:

Prinova Group LLC

Attn: Data Privacy Officer

300 Park Boulevard Suite 500

Itasca, IL 60143