EMPIRE TODAY LLC CALIFORNIA CONSUMER PRIVACY NOTICE

Updated: Effective January 31, 2022

This Empire Today LLC (“Empire,” “Company,” “us,” “we,” or “our”) California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (the “CCPA”). This Notice supplements Empire’s Privacy Policy. In the event of a conflict between any other Company policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under the CCPA.
Consistent with the CCPA, the information in this Notice and the rights described do not apply to job applicants, current and former employees/contractors, or to people whose Personal Information we collected in the context of their employment at another business (“business-to-business contact(s)”). If you are an employee, job applicant, or business-to-business contact and you have questions about how we use your Personal Information, please contact us as provided below.

1. Personal Information WE COLLECT & Why We collect it

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
Within the past 12 months, we collected the following categories of Personal Information about California consumers. Note that the specific pieces of Personal Information we collected about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

Category of Personal Information

Examples

Purposes for Collection

Categories of Recipients with which this Personal Information is shared or sold

1. Identifiers

Name, title, alias, postal address, phone number, email address, online identifier/username and password for our Service, security question/answer combinations, IP address, mobile device identifiers, signature, social media usernames

To allow you to participate in the features we offer on the Service
To process your orders and any returns/refunds
To consider applications for financing with us
To maintain your accounts with us
To communicate with you, including about our products and services, your orders, updates to our terms and policies, and to obtain your feedback
To send you marketing materials and advertisements
To allow you to participate in promotions, including sweepstakes, contests, coupons and rewards programs
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), Banking Partners, External Auditors, Government Entities.

Sale: Not Sold

2. Personal Records
Described in Cal. Civ. Code § 1798.80(e)

Name, signature, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information

Some Personal Information included in this category may overlap with other categories

To allow you to participate in the features we offer on the Service
To process your orders and any returns/refunds
To consider applications for financing with us
To maintain your accounts with us
To recognize you when you use our Service
To show you relevant ads while you browse the internet or use social media
To allow you to participate in promotions, including sweepstakes, contests, coupons and rewards programs
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers (e.g., customer service agencies, marketing firms, data analytics firms), Banking Partners, External Auditors, Government Entities.

Sale: Not Sold

3. Protected classification characteristics under California or federal law

Age, birth date, gender, marital status

To allow you to participate in the features we offer on the Service
To process your orders and any returns/refunds
To send you relevant marketing materials and advertisements
To tailor our communications to you
To improve the Service, and our products, services, marketing and advertising
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers, Banking Partners, External Auditors and Government Entities.

Sale: Not Sold

4. Commercial Information

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, communication channel preferences, coupon and loyalty program usage, information from surveys, promotions and product reviews

To allow you to participate in the features we offer on the Service
To process your orders and any returns/refunds
To consider applications for financing with us
To provide you with appropriate products, services, and recommendations
To help you find relevant products more quickly
To tailor our communications to you
To provide customer service and support
To allow you to participate in promotions, including sweepstakes, contests, coupons and rewards programs
To improve the Service, and our products, services, marketing and advertising
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers, Banking Partners, External Auditors and Government Entities.

Sale: Not Sold

5. Internet or other electronic network activity information

Browser type and language, operating system, internet or mobile network provider, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, blogs, social media pages, emails, online chat, text message communications, and advertisements

To allow you to participate in the features we offer on the Service
To facilitate, manage, personalize, and improve your website or app experience
To provide you with appropriate products, services, and recommendations
To show you relevant ads while you browse the internet or use social media
To improve the Service, and our products, services, marketing and advertising
To allow you to participate in promotions, including sweepstakes, contests, coupons and rewards programs
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers (e.g., website hosts, marketing firms, data analytics firms).

Sale: Not Sold

6. Geolocation Data

Your physical location based on information you provide directly or inferred from your IP address

To allow you to participate in the features we offer on the Service
To process your orders and any returns/refunds
To consider applications for financing with us
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes

Sharing for Business Purposes:
Service Providers (e.g., website hosts, marketing firms, data analytics firms).

Sale: Not Sold

7. Audio, electronic, visual, thermal, olfactory, or similar information

Photos or video you provide, audio data collected when you call our customer service numbers, closed circuit TV or other video recordings (for example, through video conferencing)

To help you select appropriate products for your home
To provide you with customer service
To improve our products and services, and the Service

Sharing for Business Purposes:
Service Providers (e.g., customer service / video or call recording providers).

Sale: Not Sold

8. Professional or Employment Information (as defined in CCPA §1798.140(o)(1)(I))

Information about your occupation, previous positions, salary, etc.

To consider applications for financing with us

Sharing for Business Purposes:
Banking Partners, External Auditors and Government Entities.

Sale: Not Sold

9. Inferences from other Personal Information

Information reflecting your preferences, characteristics, trends, or attitudes

To provide you with appropriate products, services, and recommendations
To improve the Service, and our products, services, marketing and advertising
To provide you with a better website or app experience
Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
To detect and prevent fraud against you and/or us

Sharing for Business Purposes:
Service Providers (marketing firms, analytics firms).

Sale: Not Sold

We may also collect Personal Information about you that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us by phone, email, text, online chat, in person, etc. We use the information included in your communications to communicate with you, including about our products and services, your orders, to provide answers to your questions, and to obtain your feedback; to provide customer service and support; to improve the Service, and our products, services, marketing and advertising; to allow you to participate in promotions, including sweepstakes, contests, coupons and rewards programs; auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes; and to detect and prevent fraud against you and/or us.  The contents of your communications with us may be shared with our Service Providers, but are not sold.
We do not sell Personal Information of individuals under 16 years of age.

2. Sources of Personal Information

We may collect your Personal Information directly from you when you provide us information online, through electronic forms, over the phone, in person, or through paper documents; automatically through our websites via cookies and other tracking technologies; from our service providers, vendors and suppliers, our affiliates, or other individuals and businesses; from third-party sources, such as data providers; and from public sources of data, such as government databases. More detail on the ways in which we collect Personal Information can be found in our Privacy Policy.

3. CALIFORNIA PRIVACY RIGHTS

California residents have the right to submit certain requests relating to their Personal Information as described below. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.
To submit a request, please use our Consumer Rights Request Form or call (866) 260-8358.
  1. THE RIGHT TO KNOW

    If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

    1. The categories of Personal Information we have collected about you
    2. The categories of sources from which the Personal Information was collected
    3. Our business or commercial purposes for collecting (or selling—if applicable) your Personal Information
    4. The categories of third parties with which we shared your Personal Information
    5. The categories of Personal Information about you that we sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
    6. The categories of Personal Information that we disclosed for a business purpose in the preceding 12 months,
    7. and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
    8. The specific pieces of Personal Information we have collected about you

    You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

  2. RIGHT TO OPT OUT OF “SALES” OF PERSONAL INFORMATION

    California residents have the right to opt out of the sale of their personal information. However, because we do not sell personal information, there is no need to submit such a request to us.

  3. RIGHT TO DELETE

    You may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will let you know what Personal Information we can delete from our records, and we will direct any of our service providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to complete a transaction or provide services to you; (2) because of an ongoing financing relationship; (3) to keep you enrolled in a promotional program; (4) for purposes of a product warranty or recall; (5) detect security incidents; (6) protect against unlawful activities; (7) identify, debug or repair errors; or (8) comply with a legal obligation. You may submit a request to delete as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

  4. NON-DISCRIMINATION AND NOTICE OF FINANCIAL INCENTIVE

    We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. This means that, consistent with California law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your Personal Information.

    We offer various promotions that provide benefits such as coupons, rebates, opportunities to participate in contests, and other benefits (together, “Promotions”). Participation in our Promotions requires you to provide some Personal Information to facilitate operation of the Promotion and to provide you with benefits associated with the Promotion. We treat the value of Personal Information collected through our Promotions as equivalent to the expenses associated with collecting and storing that Personal Information. The value of each Promotion varies, but in each case is equal to or greater than the value of the Personal Information collected to operate the Promotion. We pay the expenses associated with our Promotions and provide the Promotion benefits to foster a positive relationship with our customers and drive sales. Any value of the Personal Information collected is incidental to these purposes. By choosing to participate in one of our Promotions, you consent to any financial incentive associated with the collection of information needed to administer the program. You may withdraw from our Promotions at any time.

    Unless you specifically request, submission of a request to delete will not affect Personal Information required for you to continue to participate in any of our Promotions in which you are currently enrolled. Should you wish to delete your Personal Information associated with our Promotions (and thereby cancel your participation), please contact us as provided below.

4. HOW TO CONTACT US

For more information on your California privacy rights, please contact us at https://www.empiretoday.com/customer-service.