California Privacy Rights Act (CPRA) Notice
oUR PRIVACY POLICY AND STATEMENT
COE ORCHARD EQUIPMENT’S PRIVACY POLICY
Effective Date: July 25, 2024
Last Reviewed on: July 25, 2024
This Privacy Policy for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
This Policy also applies to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
Notice of Collection of Personal Information
We collect these categories of personal information when you interact with us: identifiers/contact information, demographic information (such as gender, race and age), biometric information, payment card information associated with you, commercial information, Internet or other electronic network activity, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
We collect this information so that we can best serve you, including fulfilling your requests, to complete a transaction or to share additional information that we think you may interested in or are relevant to your interactions with us. A more detailed description of the information we collect and the purposes for which it is collected are outlined below.
Information We Collect and Retain
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
· Publicly available information from government records.
· Deidentified or aggregated consumer information.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category
Personal Information
Examples
Collected/ Retention
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A 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, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
YES
Only retained as long as is necessary for the purpose for which the data was collected.
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
G. Geolocation data.
Physical location or movements.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
Sensitive Personal Information
Examples
Collected /Retention
(1) Personal Information that reveals:
(A) A consumer’s social security, driver’s license, state identification card, or passport number.
(B) A consumer’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 consumer’s precise geolocation.
(D) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
(E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
(F) A consumer’s genetic data.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
(2) Processing of biometric information for purpose of uniquely identifying a consumer.
Personal information collected and analyzed concerning a consumer’s health. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
YES
Only retained as long as is necessary for the purpose for which the data was collected.
We obtain the categories of personal information listed above from the following categories of sources:
· Directly from you. For example, from forms you complete or products and services you purchase.
· Indirectly from you. For example, from observing your actions on our Website.
· From third party service providers, such as worker’s compensation insurance, medical or dental insurance, or employment services providers.
· Training events, trade show forms, giveaway registrations, and social media messages.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
· To fulfill or meet the reason you provided the information. For example, if you share you name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
· To provide, support, personalize, and develop our products and services.
· To create, maintain, customize, and secure your account with us.
· To process your requests, purchases, transactions, and payments and prevent transactional fraud.
· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, and via email or text message (with your consent, where required by law).
· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
· For testing, research, analysis, and product development, including to develop and improve our products and services.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To comply with all applicable laws and regulations.
· Recruit and evaluate job applicants and candidates for employment.
· If employed by us, to manage your employment relationship with us.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our [Website users/consumers] is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
We do not sell personal information.
Personal Information Category
Category of Third-Party Recipients
Business Purpose Disclosures
Sales/Sharing
A: Identifiers.
Insurance companies, retirement companies and TPA’s, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, workers compensations insurers, worker’s compensation & drug testing clinics, federal and state DOT agencies, agencies/banks requesting employment verifications, state agencies regarding COVID-19, law enforcement.
None
B: California Customer Records personal information categories.
Insurance companies, retirement companies and TPA’s, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, worker’s compensation insurers, worker’s compensation & drug testing clinics, Federal and State DOT agencies, agencies/banks requesting employment verifications, State agencies regarding COVID-19, law enforcement
None
C: Protected classification characteristics under California or federal law.
Insurance companies, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, worker’s compensation insurers, worker’s compensation & drug testing clinics, State agencies regarding COVID-19, law enforcement
None
D: Commercial information.
Banks, IRS, law enforcement
None
E: Biometric information.
Third party payroll company, law enforcement
None
F: Internet or other similar network activity.
Law enforcement, IT company, third party payroll company
None
G: Geolocation data.
Law enforcement, third party payroll company, GPS tracking company
None
H: Sensory data.
None.
None
I: Professional or employment-related information.
Insurance companies, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, worker’s compensation insurers, worker’s compensation & drug testing clinics, State agencies regarding COVID-19, law enforcement
None
J: Non-public education information.
None
None
K: Inferences drawn from other personal information.
Insurance companies, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, worker’s compensation insurers, worker’s compensation & drug testing clinics, State agencies regarding COVID-19, law enforcement
None
Sensitive Personal Information
Business Purpose Disclosures
Sales/Sharing
(1) Personal Information that reveals:
(A) A consumer’s social security, driver’s license, state identification card, or passport number.
(B) A consumer’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 consumer’s precise geolocation.
(D) A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
(E) The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
(F) A consumer’s genetic data.
A: Insurance companies, Payroll providers, state and local authorities for the purpose of wage garnishments or child support orders, worker’s compensation insurers, worker’s compensation & drug testing clinics, State agencies regarding COVID-19, law enforcement
B: IT company, law enforcement
C: law enforcement, worker’s compensation insurer
D: law enforcement, 3rd party payroll company
E: IT company, law enforcement, worker’s compensation insurer,
F: none, do not collect.
None
(2) Processing of biometric information for purpose of uniquely identifying a consumer.
Third party payroll company and law enforcement
None
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights, below), we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• the category or categories of personal information sold or shared; and
• for disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights, below), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate personal information that we maintain about you. Once we receive your request and confirm your identity (see https://www.coeshakers.com/ccpa-policy (form below), we will review your request and use commercially reasonable efforts to correct the inaccurate personal information as directed by you.
Right to Opt Out of Sale or Sharing of Personal Information
Under the CCPA, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). However, as indicated in this policy, Coe Orchard Equipment does not currently sell or share your personal information in any capacity. Should the Company begin selling or sharing your personal information in the future, it will update this policy accordingly and provide consumers with additional information on how to Opt Out of the sale or sharing of their personal information.
Right of No Retaliation & Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
· Retaliate against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Exercising Your Rights
To exercise your rights described above, please submit a request by either:
· Calling us at 1-800-662-6677
· Emailing us at privacypolicy@coeshakers.com
· Visiting https://www.coeshakers.com/ccpa-policy (Fill out form below)
Only you, or someone legally authorized to act on your behalf, may make a request relating to your personal information.
You may only submit a request to know twice within a 12-month period. Any request relating to your personal information must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
o Verification of your name and/or relevant telephone number.
o Information regarding how your personal information was collected.
o Written request with signed verification.
o If serving as a representative to a consumer, written authorization from the consumer.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request relating to your rights.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out rights or right to limit our use of sensitive personal information, see Right to Opt Out of Sale or Sharing of Personal Information and Right to Limit Use and Disclosure of Sensitive Personal Information.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact our toll-free number at 1-800-662-6677.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hinderance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a reasonable cost estimate before completing your request.
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do no hesitate to contact us at:
Phone: 1-800-662-6677
Website: https://www.coeshakers.com/ccpa-policy
Email: privacypolicy@coeshakers.com
Postal Address:
Coe Orchard Equipment, Inc.
Attn: Carey Powell, Human Resources Department
3453 Riviera Road, Live Oak, California 95953
Phone: (530) 695.5121
If you need to access this Policy in an alternative format due to having a disability, please contact privacypolicy@coeshakers.com and/or (530) 695-5121.