Privacy Notice for Virginia Residents

Effective Date 1st June 2024

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

Pursuant to the Virginia Consumer Data Protection Act (“VCDPA”), Virginia residents have the right to be informed about the data we collect about them. This Privacy Notice applies solely to natural persons who are Virginia residents, as defined in the VCDPA. Please note that this Privacy Notice does not apply to Virginia residents who are acting as employees or job applicants. Any terms defined in the VCDPA have the same meaning when used in this Privacy Notice

The VCDPA defines “Personal Data” as “any information that is linked or reasonably linkable to an identified or identifiable natural person.” Personal Data 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 Data 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 data 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 data 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 data to respond to your inquiry. If you provide your personal data 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 to develop 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 data.

We may share your Personal Data in furtherance of the purposes described above.

We may share your Personal Data with a third party for a business purpose.  When we share Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Data for a business purpose:

Category A: Identifiers.

Category B: 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.

Category L: Some Sensitive Data as defined under Connecticut law and protected classification characteristics under Connecticut or federal law.

We share your Personal Data 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 Data in connection with products or services we provide to you.

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

The VCDPA provides Virginia residents with specific rights regarding their personal data. This section describes your VCDPA rights and explains how to exercise those rights.

Right to Confirm Processing and Access Personal Data

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• Whether we are processing personal data about you.
• The categories of personal data we collected about you.
• The categories of sources for the personal data we collected about you.
• Our business or commercial purpose for collecting or selling that personal data.
• The categories of third parties with whom we share that personal data.
• The specific pieces of personal data we collected about you (also called a data portability request).

Right to Deletion of Personal Data

You have the right to request that we delete any of your personal data 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 data, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, 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.
• 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.
• The above list is not exhaustive, and we may deny your request for any reason permitted by the VCDPA.

Right to Correct Inaccurate Personal Data

You have the right to request Prinova to correct inaccurate personal data collected about you. Prinova will make commercially reasonable efforts to correct any inaccurate personal data 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 Targeted Advertising, Sale of Personal Data, or Profiling

You have the right to opt out of the processing of personal data for the purposes of targeted advertising, the sale of personal data, or profiling.

Right to Appeal

If we deny your request to access, delete, correct, or opt-out, you have the right to appeal such decision by submitting your request to appeal here.

If your appeal is denied, you have the right to submit a complaint to the Virginia Attorney General. To file a complaint with the Virginia Attorney General, please visit: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint. 

Only you may make a verifiable consumer request related to your personal data. If you are the parent or legal guardian of a child, you may make a verifiable consumer request related to the personal data of that 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 or an authorized representative of the person we collected personal data on.
• 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 data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.  Making a verifiable consumer request does not require you to create an account with us. 

We will only use personal data 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 45 days of its receipt.  If we require more time (up to 90 days total from day of receipt), we will inform you of the reason and extension period in writing within the initial 45 day period. 

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 data 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.  In addition, we do not charge for a customer’s first two data requests, unless excessive, repetitive, or manifestly unfounded, in any given year, but VCDPA allows us to charge for responding to more than two data requests per year per customer.  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 against you for exercising any of your rights under the VCDPA, 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.

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 Personal Data, your choices and rights regarding such use, or wish to exercise your rights under Connecticut law, please do not hesitate to contact us at:

Phone:  +1 (630) 868-0300

Website:  https://prinovaglobal.com

Email: privacy@prinovaglobal.com

Address:

Prinova USA, a NAGASE Group Company

Attn: Data Privacy Officer

300 Park Boulevard Suite 500

Itasca, IL 60143