PRIVACY DISCLOSURES FOR CALIFORNIA RESIDENTS
These disclosures supplement the Privacy Policy of Sealing Devices, Inc.. (“we”, “us” or the “Sealing Devices”), which can be found at www.sealingdevices.com (the “Websites”). They are provided pursuant to the California Consumer Privacy Act (the “CCPA”), including any amendments thereto, and apply only to residents of California (“California Residents”). Each capitalized term used, but not defined, in these disclosures 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) “Cross-Context Behavioral Advertising” means the targeting of advertising to a consumer based on the consumer’s Personal 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.
(b) “Sensitive Personal Information” means all (i) Personal 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 Sealing Devices 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) Personal Information collected and analyzed concerning a California resident’s health; or (C) Personal 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 Personal Information.
(c) “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 Personal Information, including California Information, by Sealing Devices 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.
Categories of Personal Information Collected, Disclosed and Shared for a Business Purpose
In the past twelve months, Sealing Devices has collected, disclosed and Shared the following categories of California Information to the third parties, set forth below.
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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 |
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Identifiers. This includes name, address, email, and phone number. |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
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Personal 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 |
Sealing Devices discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
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Commercial Information. This includes records services provided and engagement history. |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
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Internet/Electronic Activity. This includes browsing history, search history and interaction with a website or application |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide information marketing services, technology services, data storage services, and product sales and order fulfillment services. |
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Geolocation Data. This includes device location. |
No |
N/A |
No |
N/A |
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Professional or Employment Data. Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide recruitment services, information technology services, and data storage services. |
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Education Information. Student Records. |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide recruitment services, information technology services, and data storage services. |
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Inferences drawn from other personal information. This includes information reflecting an individual’s preferences and characteristics. |
No |
N/A |
No |
N/A |
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Sensitive Personal Information. This includes 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 precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless Sealing Devices is the intended recipient of the communication; or a consumer’s genetic data. |
No |
N/A |
Yes |
Sealing Devices discloses this information to third parties who provide information technology services, data storage services, and product sales and order fulfillment services. |
Categories of Sources from which Personal Information is Collected
Sealing Devices collects California Information through the website, from third parties acting on behalf of customers, or from customers with which Sealing Devices has a business relationship, including from representatives of the customers.
Purposes for Collecting Personal Information
Sealing Devices uses California Information collected by it for one or more of the following purposes:
- To achieve the purposes for which the Personal Information was provided;
- To provide you with support, and to respond to your questions, regarding the products and services of Sealing Devices;
- To record use of Sealing Devices’ website, to diagnose problems with the website, and to improve and make the website more useful to consumers;
- To send e-mail messages, newsletters and other relevant information about Sealing Devices’ products and services;
- To consider individuals for employment or employ individuals;
- To administer employment benefits or distribute wages;
- To respond to requests from law enforcement or other governmental authorities;
- To comply with any applicable law or legal obligation;
- To prosecute or defend Sealing Devices in a legal dispute or proceeding; and
- For any other business purpose permitted by the CCPA, or any amendments thereto.
Purposes for Disclosing Personal Information
Sealing Devices does not Share or sell any Personal Information to Third Parties. Sealing Devices may disclose Personal Information—including any category of Personal Information collected by Sealing Devices—with Third Parties that enable Sealing Devices to provide products and services. Categories of Third Parties with whom Sealing Devices may disclose Personal Information include vendors that provide the following services to Sealing Devices: credit card processing, electronic billing systems, law firm accounting systems, business intelligence/financial analysis, document management systems, collaboration sites, document production, faxing, email, email management and security, learning management systems, project management, digital dictation, scheduling systems, payroll and benefits systems, contact relationship management systems, customer relations management systems, information governance systems, Cloud storage, applications for tracking and managing employee benefits data, applications used for preparing required tax forms, applications used for intellectual property or trademark management, government entities and data brokers.
Sensitive Personal Information
Sealing Devices does not collect, use or disclose Sensitive Personal Information for the purpose of inferring characteristics about Consumers, including its customers. Sealing Devices will only collect, use or disclose Sensitive Personal Information: (1) to provide the services or benefits expected by an average customer; (2) to prevent, detect and investigate security incidents that compromise the availability, integrity or confidentiality of stored or transmitted Personal Information to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes; (3) to resist malicious, deceptive, fraudulent or illegal actions directed at Sealing Devices and to prosecute those responsible for those actions, to the extent the use of your Personal 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 Personal 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 Sealing Devices, provided that the Personal Information is not disclosed to another third party and is not used to build a profile about the consumer, including clients, or otherwise alter the customer’s experience outside the current interaction with Sealing Devices; (6) to perform services on behalf of Sealing Devices, provided that the use of the customer’s Personal Information is reasonably necessary and proportionate for this purpose; and (7) to verify or maintain the quality or safety of a product, service or device that is owned, manufactured for, or controlled by Sealing Devices, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Sealing Devices, provided that the use of the customer’s Personal Information is reasonably necessary and proportionate for this purpose.
Retention of California Information
Sealing Devices keeps Personal Information, including Sensitive Personal Information, as long as it is needed to provide our services, 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:
- If Sealing Devices needs the Personal Information to operate or to provide our services, i.e. as long as the matter is active and, except in certain cases, for a period of approximately seven years after the matter is closed.
- The amount, nature, and sensitivity of the Personal Information.
- How long we need to retain the Personal Information to comply with certain legal obligations.
- If we need it for other legitimate purposes, such as to prevent harm; investigate possible violations of our terms or policies; promote safety, security and integrity; or to protect Sealing Devices and its employees, including protection of rights, property or commercial interests.
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 Sealing Devices disclose certain information to you regarding your Personal Information collected by Sealing Devices 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 Sealing Devices. Specifically, you have the right to request the following:
- The categories of Personal Information collected about you;
- The categories of sources from which the Personal Information was collected;
- Sealing Devices’ business or commercial purpose for collecting your Personal Information or, if applicable, disclosing, selling or Sharing your Personal Information;
- The categories of third parties to whom Sealing Devices discloses, sells or Shares your Personal Information; and
- The specific pieces of Personal Information collected about you.
Right to Delete Information
You may request that Sealing Devices delete any of your Personal Information retained by it, subject to certain exceptions. Upon receiving and confirming your California Request (as defined below), Sealing Devices will delete (and direct its Contractors and Service Providers to delete) such Personal Information from Sealing Devices’ (or such Contractors’ or Service Providers’) records, except that Sealing Devices may deny your request if retaining the Personal Information is necessary for Sealing Devices or one of its Contractors or Service Providers to:
- Complete the transaction for which Sealing Devices collected the Personal Information, provide requested products and services, take actions reasonably anticipated within the context of Sealing Devices’ ongoing business relationship with you, or otherwise perform a contract between Sealing Devices and you;
- 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;
- Comply with the California Electronic Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Enable solely internal uses that are reasonably aligned with Customer expectations based on a Customer’s relationship with Sealing Devices;
- Maintain internal records reasonably required for audits by external and internal auditors (including, but not limited to, accountants, banks and other financial institutions, and government authorities);
- Comply with a legal obligation; and
- Make other internal and lawful uses of Personal Information that are compatible with the context in which the Personal Information was provided.
Right to Correct Information
You may request that Sealing Devices correct your Personal Information if it is inaccurate, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. Upon receiving your California Request, Sealing Devices will use commercially reasonable efforts to correct your Personal Information.
Right to Non-Discrimination
Sealing Devices will not discriminate against an individual, including a customer, for exercising any rights under the CCPA, as amended. In particular, if a customer exercises any such rights, Sealing Devices will not:
- Deny services to a customer;
- Charge a customer different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties;
- Provide a client a different level or quality of products or services; or
- Suggest that a customer may receive a different price or rate for services, or a different level or quality of services.
However, Sealing Devices may offer a customer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any such financial incentives offered by Sealing Devices will reasonably relate to the value of Personal Information, and contain written terms that describe the material aspects of such financial incentives. A customer’s prior opt-in consent, which may be revoked at any time, is required before the customer obtains such financial incentives.
Verifiable Consumer Requests
To exercise your rights described in these disclosures and the Privacy Policy, you must submit a verifiable consumer request (a “California Request”) to Sealing Devices as set forth in the Contact Information Section of the Policy. Only you, or 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 Personal Information. You may also make a California Request on behalf of your minor child.
The California Request must:
- Provide sufficient information that allows Sealing Devices to reasonably determine you are the person about whom Sealing Devices collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows Sealing Devices to properly understand, evaluate, and respond to it.
Sealing Devices cannot respond to a request or provide Personal 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 Personal Information relates to you. Sealing Devices will only use Personal Information provided in a California Request to verify the requestor’s identity or authority to make the request.
Sealing Devices’ Response
Sealing Devices endeavors to respond to a California Request within 45 days of its receipt. If Sealing Devices requires more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. Sealing Devices will deliver its written response by mail or electronically, at your option. Any disclosures provided by Sealing Devices will only cover the 12-month period preceding receipt of the verifiable consumer request. However, if the Personal Information was collected on or after January 1, 2022 and your request is for longer than the 12-month preceding period, Sealing Devices will disclose the data requested, as long as doing so does not prove impossible or involve disproportionate effort to Sealing Devices. The response provided by Sealing Devices will, if applicable, also explain the reasons Sealing Devices cannot comply with a request. For data portability requests, Sealing Devices will select a format to provide your Personal Information that is readily useable and should allow you to electronically transmit the information from one entity to another entity without hindrance.
Sealing Devices does not charge a fee to process or respond to your California Request unless it is excessive, repetitive, or manifestly unfounded. If Sealing Devices determines that your request warrants a fee, Sealing Devices will tell you why a fee is warranted and provide you with a cost estimate before completing the request.
Revisions to These Disclosures
Sealing Devices may revise these disclosures from time to time by posting the revisions on the website. 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 website for revisions to these disclosures.
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Dated: June 1, 2024