THIS PRIVACY POLICY DESCRIBES OUR PRACTICES IN CONNECTION WITH INFORMATION WE COLLECT THROUGH GILDANBRANDS.COM, COMFORTCOLORS.COM, ANVILKNITWEAR.COM, MYGILDAN.COM, PRIMPREUX.COM, GILDANCORP.COM, BOARDOFDECORATORS.COM, AND GENUINERESPONSIBILITY.COM (THE “WEBSITES”) OR ANY OFFLINE LOCATION THAT MAKES THIS PRIVACY POLICY AVAILABLE TO YOU, HOW WE USE AND TAKES STEPS TO PROTECT THAT INFORMATION, AS WELL AS YOUR RIGHTS IN RELATION TO THIS INFORMATION. PLEASE READ THIS POLICY BEFORE VISITING THE WEBSITES OR BEFORE PROVIDING ANY INFORMATION TO US. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, YOU SHOULD IMMEDIATELY DISCONTINUE ANY USE OF THE WEBSITES. BY USING THE WEBSITES AND PROVIDING US WITH INFORMATION, YOU AGREE TO OUR TERMS OF USE AND CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION, AND OTHER ACTIVITIES AS DESCRIBED IN THIS PRIVACY POLICY. ALSO NOTE THAT THIS PRIVACY POLICY AND TERMS AND CONDITIONS MAY CHANGE FROM TIME TO TIME AND IT IS YOUR RESPONSIBILITY TO CHECK FOR SUCH UPDATES. THE LAST REVISION DATE FOR THIS PRIVACY POLICY AND TERMS AND CONDITIONS IS SET FORTH BELOW.

If you are a Nevada resident or California resident, please see the “Additional Disclosures for Nevada Residents” and “Additional Disclosures of California Residents” sections.

1. The Websites are owned and operated by Gildan Activewear SRL (hereinafter the “Site Owner” or “we”, or “us”). Your use of the Websites, and your interactions with us offline, are subject to the following terms and all applicable laws.

2. Purpose of Collection of Information. We collect information from you when you voluntarily provide it to us, it is automatically collected, or collected from other sources. It can be in connection with your purchases on the Websites, your subscription to emails and newsletters, your feedback on purchases, your participation to contests and any other type of activities for which you would need to provide your information. You can choose not to provide certain information, but then you might not be able to take advantage of certain of our products or services.

3. Collection of Information. The Site Owner obtains its information about you directly from you. Depending on the type of product or service requested, the Site Owner may require information such as your name, birthday, gender, country, address, shipping address, email address, telephone number, credit card number, expiration date, security code, your interests, inferences, preferences and favorites, any content you share within messages you send us, or when you apply for a job and provide us with employment and education history, your transcript(s), writing samples, and references, account credentials, including your username, password, password hints, and information for authentication and account access, and other additional information. We also collect personal contacts data, including the first and last name and email address of your personal contacts. We collect data about your contacts with your consent and in order to fulfill a request by you, such as inviting your contacts to use the Websites. Such functionality is only intended for U.S. residents. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent for us to use their contact information to fulfill your request.

You may choose to voluntarily provide other information to us that we do not request, and in such instances, you are solely responsible for such information.

In addition, we collect other information automatically when you use the Websites, including IP addresses, Ad Id, aggregate user data, site usage information, emails and advertisements you view, products you view and purchase, time of day you browse, your referring and exiting pages, and browser type, operating software, your internet service provider, your device’s regional and language settings to help diagnose problems with our server, manage and improve the Websites, track usage, and for security and monitoring purposes. This information aids us in merchandizing and improving the design and layout of the Websites. We also collect imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).

We also collect information from other sources. The following are the categories of sources from which we collect information:

• Consumer or users of the Websites.
• Data brokers or resellers from which we purchase data to supplement the data we collect.
• Social networks when you engage with our content, reference our Websites, or grant us permission to access information from the social networks.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly-available sources, including data in the public domain.

4. Cookies and Analytics Tools. We use various current, – and later-developed, tracking technologies to automatically collect information when you use the Websites, including the following:

• Log Files, which are files that record events that occur in connection with your use of the Websites;
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Websites and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Websites. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. To learn more about how we use cookies, please see our cookie policy here.
• Pixels (also known as web beacons), which is code embedded in a website, video, email or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us track our conversions, bring you advertising both on and off the Websites, and provide you with additional functionality, such as the ability to connect our Websites with your social media account.
• Website heat maps, which is code embedded in a website that sends user movement data to a server. Website heat maps include scroll maps, clicks maps, and move maps. We use website heat maps to help us determine the most popular and unpopular areas of our website and to help us better understand how users interact with our website.
• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
•  App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Websites, and provide you with additional functionality.
• Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights Over Your Information” sections below.

5. Use of Information. We collect and use your information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include: (1) processing your orders and other requests; (2) responding to your comments, questions, and requests, and providing customer service; (3) contacting you to confirm your order, including sending you emails to acknowledge your order and confirm your order status and shipment or if there is a difficulty in completing or shipping your order; (4) responding to your requests; (5) administering contests and other promotions in which you participate; (6) improving your customer experience and our marketing efforts, products and services; (7) enforcing this Privacy Policy or the Websites Terms of Use; (8) developing and sending you marketing, including, newsletters and advertisements; (9) sending you promotional emails; (10) informing you of new products, services and offers; (11) operating and managing the Websites, including your registration and account; (12) sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administer messages; (13) preventing and addressing fraud and threats of harm; (14) monitoring and analyzing trends, usage, and activities; (15) conducting research, including focus groups; and (16) fulfilling any other business or commercial purposes at your direction or with your notice and/or consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights Over Your Information” section below.

6. The Legal Basis on Which We Use Your Information. In some jurisdictions, we must have a legal basis to process your information. In some cases this may be to fulfill our contractual obligations to you, for example to process your orders, or contact you with order information.

We may also process your information to meet our or a third party’s legitimate interests, for example, to understand how you use our services and to derive knowledge from that to enable us to develop new services and to improve your customer experience. When we process information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests or those of a third party are not overridden by your interests or fundamental rights and freedoms.

We may obtain your consent to collect and use certain types of information when we are required to do so by law (for example, in relation to the use of cookies and tracking technologies). We also process your information when you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners. If we ask for your consent to process your information, you may withdraw your consent at any time by contacting us using the details in the “Contact Information” section below.

We may also process your information to comply with our legal obligations, for example, to comply with applicable tax/revenue laws, resolve disputes or enforce our agreements.

7. Sharing of Information. We share your information in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have shared information include the following:

• Service Providers. We share information with companies that process information on our behalf for our business purposes. Service provides assist us with data analytics, digital marketing and creating better consumer experiences, management and maintenance of the Websites or to deliver the products, services or information you request, facilitating some aspects of our Site, sending email, fulfilling purchase requests, delivering orders, processing credit cards and payment information, verification, fraud prevention, credit card authorization, serving, customizing or delivering marketing material, and auditing. These companies may be supplied with or have access to your information solely for the purpose of providing these services to us or on our behalf. We have agreements with these companies that prevent them from using your information for any purpose other than what we require them to do with it, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Vendors or Other Parties. We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
• Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
• Affiliates. We share information with our related entities including our parent and sister companies for purposes such as customer support, marketing, and technical operations.
• Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials. Public Forums. We share information you make public through the Website, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights Over Your Information” section below.
• We share information for administrative and other purposes that it deems necessary to maintain, service, and improve our products and services or in the event that all or substantially all of our assets are acquired by a third party.
• Security Disclosures. We share your information to identify, contact or bring legal action against someone who we believe is in violation of the rights protect the legal rights of Gildan Activewear SRL and its affiliated companies, their employees, agents and contractors, to protect the safety and security of visitors to our Websites and anyone else, and to protect against fraud or for risk management purposes; or
• Compelled Disclosure. We share information to comply with the laws or legal processes of the United States, Canada, or other countries, and were required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• Merger or Acquisition. We share information in the event of, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of Site Owner’s assets, or transfer of all or a portion of Site Owner’s business to another business.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights Over Your Information” section below.

8. Social Media and Technology Integrations. We offer parts of the Websites through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Websites. Some examples include:

• Links to websites, platforms, social media sites, and other services not operated or controlled by us. Other parties may collect information about your online activities over time and across different websites when you visit the Websites. If you would like additional information about online tracking and various opt-out mechanisms, please see the “Analytics and Advertising” section below.
• Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Websites that allow you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
• Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Websites on social media (e.g., by using a hashtag associated with Site Owner in a tweet or post), we may use your reference on or in connection with our Websites.

Site Owner is not responsible for the privacy practices or the content of these other entities and any information that you provide to such other entities, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere, shall be subject to the privacy policies of the owners of such other entities. Site Owner encourages you to familiarize yourself with and consult their privacy policies and terms of use.

9. Analytics and Advertising. We use analytics services, such as Google Analytics, to help us understand how users access and use the Websites. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Websites (including emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Websites or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Websites, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Websites and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Websites and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Collection of Information” and “Your Rights Over Your Information” sections.

10. International Transfers. We operate a global business. By using our services, you understand that we may transfer some of the information we gather to the United States for storage purposes.

The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.

We have put in place and maintain reasonable and appropriate administrative, physical, and technical security safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place please see the “Security and Risks Related to Internet” section below or contact us at the details below.

11. Information Retention. We will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Gildan Brands member account), as described in this policy, or as needed to provide services to you. If you no longer want the Site Owner to use your information to provide services to you, you may close your account. Site Owner will retain and use your information to the extent necessary to comply with legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files that are only used in the event an order is abruptly ended. These log files are generally retained for a brief period of time, except in cases where we are legally obliged to retain them for longer periods.

12. Your Rights With Respect to Your Information. You have certain rights regarding your information, subject to local law. These include the right to access your information, rectify the information we hold about you, erase your information, restrict our use of your information, object to our use of your information, receive your information in a useable electronic format and transmit it to a third party (right to data portability) and lodge a complaint with your local data protection authority. If you would like to discuss or exercise such rights please contact the Site Owner’s Privacy Officer, Andrew Colvin at Privacyofficer@gildan.com, or if you are a California or Nevada resident, please see additional disclosures below.  

We encourage you to contact us to update or correct your information if it changes or if the information we hold about you is inaccurate.

We will contact you if we need additional information from you in order to honour your requests.

For cookies and pixels, most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Websites may not function correctly.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Information” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out. For Facebook, you can change your settings here. For Google, you can change your setting here

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.

13. Security and Risks Related to Internet. The Websites have security measures in place to help protect against the loss, theft, misuse and unauthorized access, disclosure, alteration and destruction of the information under the Site Owner’s control. The Websites use no encryption (data scrambling) on certain portions of the Websites, but use encryption on portions where you are transmitting financial information, such as credit card information. When you are on any website that asks you for confidential information, you should check to see if the information being transmitted is encrypted in order to increase the security of your information. Although every effort is made to ensure no one else will view, seize or obtain your information, complete confidentiality and security is not yet possible over the Internet. Any unencrypted email communication over the Internet is not secure or confidential, and is subject to possible interception, loss and alteration. The Site Owner, its agents, administrators, employees and affiliates may not be held liable for any damages you or anyone else may suffer or incur as a result of the transmission of confidential or sensitive information over the Internet, and all such communications will be made at your own risk.

14. Monitoring. The Site Owner may, from time to time, monitor access to, use of and other activities relating to the Websites for the purposes of maintenance of the Websites, reviewing proper and legal use of the Websites and security-related issues. The Site Owner may intervene in relation thereto but does not make any representation or warranty that it will do so. You hereby consent to any such monitoring and intervention.

15. Use of Information by Employees of the Site Owner. Certain employees of the Site Owner or of its affiliates may be provided with information about you in order to provide services or information that you have requested regarding specific products or services. These employees are instructed to use strict standards of care in handling your information.

16. YOU HEREBY EXPRESSLY CONSENT TO THE DISCLOSURE BY THE SITE OWNER OF YOUR INFORMATION TRANSMITTED THROUGH THE WEBSITES TO THE SITE OWNER’S EMPLOYEES AND TO THE SITE OWNER’S AFFILIATES’ EMPLOYEES IN ORDER TO ALLOW THEM TO PROVIDE YOU WITH THE PRODUCTS AND SERVICES THAT YOU MAY REQUEST. YOU HAVE THE RIGHT TO WITHDRAW YOUR CONSENT AT ANY TIME.

17. Information about Products and Services. The Site Owner may occasionally send you e-mail messages about products and services where you have specifically consented to receive such information. If you do not wish to receive such mailings, you may do so by cancelling your subscription to such email messages by contacting the Site Owner at contact@boardofdecorators.com or by following the instructions as provided in emails to click on the unsubscribe link. Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.

18. Children’s Policy. The Websites are intended for a general audience, and are not directed at children under thirteen (13) years of age.

We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. Please do not allow children under the age of 13 to provide any personal information through the Websites. If we learn that a child under the age of 13 has provided personal information in violation of our Privacy Policy, we will delete that information as soon as practical and to the extent required by applicable law. If you learn that a child under the age of 13 has provided personal information to us, please send us an email at privacyofficer@gildan.com. We will delete this information to the extent required by applicable laws.

We do not knowingly “sell”, as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

If you are a California resident under 18 years old and registered to use the Websites, you can ask us to remove any content or information you have posted on the Websites. To make a requests, email us at the email address set out in the “Contact Information” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  

19. Severability. If any provision hereof is held illegal, invalid or unenforceable by any competent authority in any jurisdiction, such illegality, invalidity or unenforceability shall not in any manner affect or render illegal, invalid or unenforceable such provision in any other jurisdiction or any other provision hereof in any jurisdiction.

20. Modification of this Privacy Policy. We may modify, alter or otherwise update the Privacy Policy applicable to the Websites, in our sole discretion, from time to time, by updating this posting. The date of the last modification will appear at the top hereof. We will provide additional notice in advance (e.g., a disclaimer on our Websites or an email to subscribers) if material changes are being made, specifically if we make significant changes to how we handle information. You should review this Privacy Policy each time you access and use the Websites. Your access and use of the Websites constitutes irrefutable evidence of your consent to be bound by these terms and conditions.

21. Governing Law. This Privacy Policy shall be governed by the laws of the State of New York applicable thereto without reference to principles of conflict of laws. You agree to be bound by such laws.

Any dispute, controversy or claim arising out of or in connection with these terms or the use of the Websites, including any matters regarding the validity or application of the terms of use, is subject to the exclusive jurisdiction of any state or federal court located in the State of New York, United States of America.

22. Jurisdiction. The Websites are controlled and operated by the Site Owner from Newton Christ Church BB 17047, Barbados.

23. Contact Information. All complaints and requests for access to, or modification or destruction of information may be made to Site Owner’s Privacy Officer who can be reached by any of the following means:

Email: privacyofficer@gildan.com

Mail: Gildan Activewear SRL
To the attention of Andrew Colvin, Privacy Officer
Newton Christ Church BB 17047
Barbados

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the country in which you are a resident.

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at privacyofficer@gildan.com.

24. Additional Disclosures for Nevada Residents. Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at privacyofficer@gildan.com.

25. Additional Disclosures for California Residents. These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

Our Websites are intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, office, or contractor or (ii) Site Owner conducting due diligence regarding, or providing or receiving a product or service to or from your employer.

A. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, email address, phone number, account name, IP address, and an ID or number assigned to your account.
• Customer records, billing and shipping address, and credit or debit card information.
• Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
• Commercial information, including purchases and engagement with the Websites.
• Internet activity, including your interactions with our Websites.
• Audio or visual data, including pictures or videos you post on our Websites.
• Employment and education data, including information you provide when you apply for a job with us.
• Inferences, including information about your interests, preferences and favorites.

For more information on information we collect, including the sources we receive information from, review the Collection of Information section. We collect and use these categories of personal information for the business purposes described in the Use of Information section, including to provide and manage our Websites.

Under the CCPA, “sell” is defined broadly, and some of our data sharing practices may be considered a “sale.” Site Owner does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Analytics and Advertising section as a “sale,” we will comply with applicable law as to such activity. Site Owner discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Websites. Please review the Sharing of Information section for more detail.

B. Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Information” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

This Privacy Policy is effective as at: January 2020.