CALIFORNIA PRIVACY NOTICE
Last Updated: September 9, 2021
This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ("consumers" or "you").
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined the CCPA. Brava® is a registered trademark of Brava Home, Inc.
1. Scope
When we use the term “personal information” in these CA Disclosures, we 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 consumer or household.
For the purposes of these CA Disclosures, personal information does not include:
· Publicly available information from government records.
· Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
· Information excluded from the CCPA's scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
· Information relating to our employees, contractors and other personnel.
2. COLLECTION AND USE OF PERSONAL INFORMATION
We collect personal information from and about you for a variety of purposes. For example, we use personal information:
· To fulfill your requests, process your transactions and provide our Services to you
· To communicate with you
· For marketing and advertising purposes
· Conduct research and analytics designed to understand our customer base and improve our products, services and customer experience;
· To protect the security and integrity of our business, comply with legal requirements and obligations, and as otherwise permitted or required by law.
To learn more about the types of personal information we collect, please refer to the Information We Collect On or Through the Service section of our Privacy Policy. To learn more about the purposes for which we use this information, please refer to How We Use the Information section of our Privacy Policy.
In the last 12 months, we have collected the following categories of personal information:
| Category of Personal Information Collected | Collected | Categories of Sources |
| Identifiers, such as your name, address, phone number, email address, IP address, or other similar identifiers. |  | · Directly from you · Our business partners and affiliates · Third parties you direct to share information with us · Social networks |
| California Customer Records (Cal. Civ. Code § 1798.80(e)), such as billing address and payment information. | | · Directly from you · Our business partners and affiliates · Third parties you direct to share information with us |
| Protected Classification Characteristics, such as age, gender, and number of individuals in the household. | | · Directly from you · Our business partners and affiliates · Third parties you direct to share information with us |
| Commercial Information, such as shopping and purchase history. | | · Directly from you · Your browser or device |
| Internet/Network Information, such as device information, browsing activity, logs, and analytics data. | | · Your browser or device |
| Geolocation Data, such as precise location information from your device or generated based on IP address. | | · Your browser or device |
| Sensory Information, such recordings of phone calls with us, where permitted by law. | | · Directly from you |
| Profession/Employment Information in connection with job applications, such as your employment and educational history, or related information included in your applicant documents. | | · Directly from you · From third parties you direct to share information with us |
| Other Personal Information, including communication preferences, information you post on our social media pages, cooking history and related data, or other information you provide to us in relation to a question, request, inquiry survey, contest or promotion. | | · Directly from you · From third parties you direct to share information with us · Your browser or device |
| Inferences, such as predictions about your interests, and cooking dietary, and other lifestyle preferences. | | · Your browser or device · Information generated or derived from your purchases, online browsing and usage activity |
3. DISCLOSURE OF PERSONAL INFORMATION
As described in the How We Share Your Information section of our Privacy Policy, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales below).
The categories of third parties to whom we sell or disclose your personal information for a business purpose include:
· Other Brava Brands and affiliates.
· Service providers and advisors that perform services for us, on our behalf, which may include providing payment processing services, marketing and advertising services, providing mailing or email services, tax and accounting services, fraud prevention, web hosting, or similar services;
· Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
· Ad networks and advertising partners to deliver advertising and personalized content to you on our Service, on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics and market research;
· Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
· Social networks for advertising or personalization purposes, or to engage with you.
· We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Policy.
In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:
· All of the categories of personal information we collect, explained in the table above.
In the previous 12 months, we have sold the following categories of personal information to third parties, subject to your settings and preferences and your Right to Opt Out:
· Personal Identifiers
· Commercial Information
· Internet / Network Information
As is common practice among companies that operate online, we have permitted third party advertising networks, social media companies and other third party businesses collect and disclose your personal information (including Internet / Network Information, Commercial Information, and Inferences) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. To learn more, please see the Third-Party Tracking and Online Advertising section of our Privacy Policy.
4. YOUR CALIFORNIA CONSUMER RIGHTS
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
| The Right to Know | You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: · The specific pieces of personal information we have collected about you; · The categories of personal information we have collected about you; · The categories of sources of the personal information; · The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; · The categories of personal information we have sold and the categories of third parties to whom the information was sold; and · The business or commercial purposes for collecting or selling the personal information. |
| The Right to Request Deletion | You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
| The Right to Opt Out of Personal Information Sales | You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. |
| The Right to Non-Discrimination | You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
| “Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). |
5. TO EXERCISE YOUR CALIFORNIA CONSUMER RIGHTS
To Exercise Your Right to Know or Right to Deletion
To exercise your Right to Know or your Right to Request Deletion, please submit a request by:
· Filling out our California Consumer Rights Request Form, or
· Calling (855) 276-6767
We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To Exercise Your Right to Opt Out of Personal Information Sales
Unless you have exercised your Right to Opt Out of personal information sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.
To exercise the Right to Opt Out of Personal Information Sales, you may submit a request by clicking the following link:
Third Party Tracking and Online Advertising
We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use your personal information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
Please see the Third-Party Tracking and Online Advertising section of our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those activities.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at privacy@brava.com inform us if you, or your minor child, are under the age of 16.
California’s “Shine the Light” Law
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click Do Not Sell My Info and provide your contact information to be added to our suppression list.
6. ADDITIONAL INFORMATION
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@brava.com.