Cookware Company (USA), LLC
Privacy Disclosures for California Residents
These disclosures supplement the Privacy Policy (the “Policy”) of The Cookware Company (USA), LLC, a Delaware limited liability company, (“CWC”), which can be found at https://www.greenpan.us/ (the “Site”). These supplemental privacy disclosures (“Disclosures”) are provided pursuant to the California Consumer Privacy Act (“CCPA”), as amended, and apply only to residents of California. Each capitalized term used, but not defined in these Disclosures or the Policy, shall have the meaning given to such term in the CCPA.
Definitions
Capitalized terms shall have the same meaning as the terms defined in the Policy. In addition, in these Disclosures:
(a) “"California Information” means all California Information that relates to residents of California and that is covered by the California Consumer Privacy Act or the California Online Privacy Protection Act, including any amendments thereto.
(b) “Cross-Context Behavioral Advertising” means the targeting of advertising to a consumer based on the consumer’s California Information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.
(c) “Sensitive Personal Information” means all (i) California Information that reveals (A) a California resident’s social security, driver’s license, state identification card, or passport number; (B) a California resident’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a California resident’s precise geolocation; (D) a California resident’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a California resident’s mail, email and text messages, unless CWC is the intended recipient of the communication; (F) a California resident’s genetic data; and (2) (A) the processing of biometric information for the purpose of uniquely identifying a California resident; (B) California Information collected and analyzed concerning a California resident’s health; or (C) California Information collected and analyzed concerning a California resident’s sex life or sexual orientation; Sensitive Personal Information that is “publicly available” pursuant to the California Laws is not considered Sensitive Personal Information or California Information.
(d) “Share,” “Shared,” or “Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s California Information, including California Information, by CWC to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for Cross-Context Behavioral Advertising for the benefit of a business in which no money is exchanged.
Required Disclosures
Categories of California Information Collected, Disclosed and Shared for a Business Purpose
In the past twelve months, CWC has collected, disclosed and Shared the following categories of California Information to the third parties, set forth below.
|
Categories of California Information We Collect |
Is California Information Shared |
Categories of Third Parties with Which We Share California Information |
Is California Information Disclosed |
Categories of Third Parties to Which we Disclose California Information |
|
Identifiers. This includes name, address, email, and phone number. |
No |
N/A |
Yes |
CWC discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
|
California Information categories listed in the California Customer Records statute. This includes, name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. |
No |
N/A |
Yes |
CWC discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
|
Commercial Information. This includes records of products purchased or considered or other purchasing or consuming histories or tendencies. |
No |
N/A |
Yes |
CWC discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
|
Internet/Electronic Activity. This includes browsing history, search history and interaction with a website or application |
Yes |
CWC may Share California Information with our marketing and advertising providers. |
No |
N/A |
|
Geolocation Data. This includes device location. |
Yes |
CWC may Share California Information with our marketing and advertising providers. |
No |
N/A |
|
Inferences drawn from other California Information. This includes information reflecting an individual’s preferences and characteristics. |
Yes |
CWC may Share California Information with our marketing and advertising providers. |
No |
N/A |
|
Sensitive Personal Information. This includes a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; a consumer’s precise geolocation; a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless CWC is the intended recipient of the communication; or a consumer’s genetic data. |
No |
N/A |
No |
N/A |
Categories of Sources from which California Information is Collected
CWC collects California Information through the Site, from third parties acting on behalf of Consumers, or from customers with whom or which CWC has a business relationship, including from representatives of CWC’s customers.
Purposes for Collecting California Information
CWC uses California Information collected by it for one or more of the following business purposes:
Purposes for Sharing California Information
CWC Shares California Information with third parties which provide analytics services and serve ads on our behalf targeted to your interests and based on your online activities. Information may be linked to your browser or device (like cookies and similar tracking technologies) and related to you if you have a customer account or interact with us in other ways.
Purposes for Disclosing California Information
CWC may disclose California Information, including any category of California Information collected, with third parties, including Contractors or Service Providers, to enable CWC to provide products and services, and otherwise conduct its business operations.
No Knowledge of California Information Sold or Shared for Consumers Under Sixteen
In the preceding twelve months, to its knowledge, CWC has not sold or Shared any California Information of Consumers under sixteen years of age with any third parties.
Sensitive Personal Information
CWC does not collect, use or disclose Sensitive Personal Information for the purpose of inferring characteristics about Consumers. CWC will only collect, use or disclose Sensitive Personal Information: (1) to provide the services or benefits expected by an average consumer; (2) to prevent, detect and investigate security incidents that compromise the availability, integrity or confidentiality of stored or transmitted California Information to the extent the use of your California Information is reasonably necessary and proportionate for these purposes; (3) to resist malicious, deceptive, fraudulent or illegal actions directed at the business and to prosecute those responsible for those actions, to the extent the use of your California Information is reasonably necessary and proportionate for these purposes; (4) to ensure the physical safety of natural persons, to the extent the use of your California Information is reasonably necessary and proportionate for these purposes; (5) for short-term, transient use, including, but not limited to, non-personal advertising shown as part of a consumer’s current interaction with the business, provided that the California Information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; (6) to perform services on behalf of the business, provided that the use of the consumer’s California Information is reasonably necessary and proportionate for this purpose; and (7) to verify or maintain the quality or safety of a produce, service or device that is owned, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business, provided that the use of the consumer’s California Information is reasonably necessary and proportionate for this purpose.
Retention of California Information
CWC keeps California Information as long as it is needed to provide our products, comply with legal obligations or protect our interests. We decide how long we need information on a case-by-case basis. The following factors are taken into consideration when making such a determination:
Summary of Consumers’ Rights
The following is a summary of a Consumer’s rights under the CCPA, including any amendments thereto:
Right to Know Specific Information
You have the right to request that CWC disclose certain information to you regarding your California Information collected by CWC in the preceding 12 month period or, if requested and the data was collected on or after January 1, 2022, beyond the 12 month period, as long as doing so does not prove impossible or involve disproportionate effort on CWC. Specifically, you have the right to request the following:
Right to Delete Information
You may request that CWC delete any of your California Information retained by it, subject to certain exceptions. Upon receiving and confirming your California Request (as defined below), CWC will delete (and direct its Contractors and Service Providers to delete) such California Information from CWC’s (or such Contractors’ or Service Providers’) records, except that CWC may deny your request if retaining the California Information is necessary for CWC or one of its Contractors or Service Providers to:
Right to Correct Information
You may request that CWC correct your California Information if it is inaccurate, taking into account the nature of the California Information and the purposes of the processing of the California Information. Upon receiving your California Request, CWC will use commercially reasonable efforts to correct your California Information.
You may opt out of the processing of your California Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising. A link to the opt out page can be found on the Site’s homepage.
Right to Non-Discrimination
CWC will not discriminate against a Consumer for exercising any rights under the CCPA, as amended. In particular, if a Consumer exercises any such rights, CWC will not:
However, CWC may offer a Consumer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any such financial incentives offered by CWC will reasonably relate to the value of California Information, and contain written terms that describe the material aspects of such financial incentives. A Consumer’s prior opt-in consent, which may be revoked at any time, is required before the Consumer obtains such financial incentives.
To exercise your rights described in these disclosures and the Policy, you must submit a verifiable consumer request (a “California Request”) to CWC as set forth in the Contact Information Section of the Policy. Only you, or a an agent registered with the California Secretary of State that you authorize to act on your behalf, may make a California Request relating to your California Information. You may also make a California Request on behalf of your minor child.
The California Request must:
CWC cannot respond to a request or provide California Information if it cannot verify your identity or the individual’s authority to make the request on your behalf unless it can confirm that the California Information relates to you. CWC will only use California Information provided in a California Request to verify the requestor’s identity or authority to make the request.
CWC endeavors to respond to a California Request within 45 days of its receipt. If CWC requires more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. CWC will deliver its written response by mail or electronically, at your option. Any disclosures provided by CWC will only cover the 12-month period preceding receipt of the verifiable consumer request. However, if the California Information was collected on or after January 1, 2022 and your request is for longer than the 12-month preceding period, CWC will disclose the data requested, as long as doing so does not prove impossible or involve disproportionate effort to CWC. The response provided by CWC will, if applicable, also explain the reasons CWC cannot comply with a request. For data portability requests, CWC will select a format to provide your California Information that is readily useable and should allow you to electronically transmit the information from one entity to another entity without hindrance.
CWC does not charge a fee to process or respond to your California Request unless it is excessive, repetitive, or manifestly unfounded. If CWC determines that your request warrants a fee, CWC will tell you why a fee is warranted and provide you with a cost estimate before completing the request.
Revisions to These Disclosures
CWC may revise these disclosures from time to time by posting the revisions on the Site. Any such revision will take effect immediately upon such posting, but will only relate to California Information collected after such revision is posted. It is a Consumer’s responsibility to periodically check the Site for revisions to these disclosures.
Effective Date: June 30, 2023