California Privacy Disclosure

The 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”). They are provided pursuant to the California Consumer Privacy Act (“CCPA”) and apply only to residents of California. Each term used in these disclosures that is defined in the CCPA, but not defined herein, shall have the meaning given to such term in the CCPA.

 

Required Disclosures

 

Categories of Personal Information Collected

The following categories of personal information are collected by CWC:

 

• Identifiers (g., name, Internet protocol address, email address, physical address, and phone number);
• Customer records information (including, but not limited to, financial account number, credit card number, debit card number, or other financial information);
• Internet and network activity information;
• Commercial information (including, but not limited to, information relating to (1) a customer’s personal property, and (2) products or services acquired or considered by a customer); and
• Profile inferences.

 

Categories of Sources of Personal Information Collected

 

CWC obtains personal information from consumers using the Site (as defined in the Policy), individuals or entities using the Site on behalf of consumers, or individuals or entities with whom or which CWC has a business relationship.  CWC may also obtain personal information from employees in the ordinary course of business.

 

Purposes for Collecting Personal Information

CWC uses personal information collected by it for one or more of the following purposes:

 

• To achieve the purposes for which personal information was provided;
• To provide products and services to customers;
• To record use of the Site, diagnose problems with the Site, and improve and make the Site more useful to users;
• To send e-mail messages, newsletters and other correspondence regarding CWC and its products and services;
• To process payments for CWC’s products and services;
• To consider consumers for employment, or employ consumers;
• To respond to requests from law enforcement or other governmental authorities;
• To comply with any applicable law or other legal obligation;
• To prosecute, or defend itself in, a legal dispute or proceeding; and
• For any other business purpose permitted by the CCPA.

Categories of Third Parties with whom CWC Shares Personal Information

CWC does not sell any personal information to third parties.  CWC may share personal information with third parties that enable CWC to provide products and services and otherwise conduct its business operations.  Categories of third parties with whom or which CWC may share personal information include the following:

 

• Credit card processing systems;
• Billing systems;
• Accounting systems;
• Business intelligence and financial analysis systems;
• Document management systems;
• Email and facsimile management systems;
• Project management systems;
• Scheduling systems;
• Marketing automation systems;
• Contact relationship management systems; and
• Other cloud storage systems.

Summary of Consumers’ Rights

The following is a summary of a consumer’s rights under the CCPA:

 

Right to Access Personal Information

Consumers have the right to request that CWC disclose certain information to them regarding their personal information as follows:

 

• The categories of personal information collected by CWC;
• The categories of sources of personal information collected by CWC;
• CWC’s business or commercial purpose for collecting or, if applicable, sharing personal information;
• The categories of third parties with whom or which CWC shares personal information;
• The specific pieces of personal information collected by CWC; and
• The categories of personal information, if any, CWC disclosed for a business purpose to a third party in the preceding 12 months.

 

Deletion Rights

Consumers may request that CWC delete any personal information retained by CWC, subject to certain exceptions.  Upon receiving and confirming a verifiable consumer request, CWC will delete (and direct its service providers to delete) personal information from CWC’s (or such service providers’) records, except that CWC may deny a request if retaining the personal information is necessary for CWC or one of its service providers to:

 

• Complete the transaction for which CWC collected personal information, provide any requested products, take actions reasonably anticipated within the scope of CWC’s ongoing relationship, or perform a contract between CWC and a consumer;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activity;
• Debug products to identify and repair errors that impair intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided by law;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with CWC;
• Comply with a legal obligation; and
• Make other internal and lawful uses of personal information that are compatible with the context in which it was provided.

 

Verifiable Consumer Requests

 

To exercise any rights described in these disclosures, a consumer must submit a verifiable consumer request to CWC as set forth in the Policy.  Only a consumer, or a person registered with the California Secretary of State that a consumer authorizes to act on behalf of the consumer, may make a verifiable consumer request relating to personal information. A consumer may also make a verifiable consumer request on behalf of a minor child.

 

A verifiable consumer request for access to personal information or data portability can only be made by a consumer twice within a 12-month period. The verifiable consumer request must:

 

• Provide sufficient information that allows CWC to reasonably determine that the consumer is the person about whom CWC collected personal information or an authorized representative; and
• Describe the request with sufficient detail that allows CWC to properly understand, evaluate, and respond to it.

 

CWC cannot respond to a request or provide personal information if it cannot verify the consumer’s identity or authority to make the request, and confirm the personal information relates to the consumer.  CWC will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

CWC’s Response

CWC endeavors to respond to a verifiable consumer request within 45 days after its receipt.  If CWC requires more time (up to an additional 45 days), CWC will inform the consumer of the reason and extension period in writing.  CWC will deliver its written response by mail or electronically, at the consumer’s option.   Any disclosures provided by CWC will only cover the 12-month period preceding receipt of the verifiable consumer request.  The response provided by CWC will, if applicable, also explain the reasons it cannot comply with any portion of the request.  For data portability requests, CWC will select a format to provide personal information that is readily useable and should allow the consumer to electronically transmit the information from one entity to another entity without hindrance.

 

CWC does not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If CWC determines that any request warrants a fee, it will tell the consumer why a fee is warranted and provide the consumer with a cost estimate before completing the request.

 

No Discrimination

CWC will not discriminate against a consumer for exercising any rights under the CCPA.  In particular, if a consumer exercises any such rights, CWC will not:

 

• Deny services or access to a consumer’s file;
• Charge a consumer different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide a consumer a different level or quality of services; or
• Suggest that a consumer may receive a different price or rate for services, or a different level or quality of services.

Revisions

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 personal information collected after such revision is posted.  It is a consumer’s responsibility to periodically check the Site for revisions to these disclosures.

 

Dated:  June 8, 2021