Notice to California Residents – Your California Privacy Rights
Effective Date: July 1, 2020
Last Updated Date: February 21, 2023
This California Consumer Privacy Policy (the “Policy”) supplements the privacy statement on www.tobaccorights.com and applies to personal information collected both online and offline solely about individuals who are California residents.
This Policy uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
- Notice of Collection and Use of Personal Information
We may collect and may have collected during the 12-month period prior to the last updated date of this Policy the following categories of personal information about you:
- Identifiers: identifiers such as a real name, postal address, unique personal identifiers (such as a device identifier; cookies, beacons, pixel tags, and similar technology; customer number; telephone number and other forms of persistent or probabilistic identifiers), IP address, email address, and other similar identifiers
- Customer Records Data (Subject to Cal. Civ. Code § 1798.80): signature, and physical characteristics or description
- Protected Classifications: characteristics of protected classifications under California or federal law, such as age, gender, and ethnicity/race/national origin
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Sensory Information: audio, electronic and similar information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes
We do not collect personal information that is deemed “sensitive” under the CCPA.
We may use and may have used during the 12-month period prior to the last updated date of this Policy your personal information for the purposes described in the privacy statement on www.tobaccorights.com and for the following business purposes specified in the CCPA:
- Outreach regarding legislative, regulatory, or election-related issues
- Looking at site trends, customer interests, and for security purposes
- Performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Conducting internal research for technological development and demonstration
- Retention of Personal Information
We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the privacy statement on the www.tobaccorights.com website and this Policy, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
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Sources of Personal Information
During the 12-month period prior to the last updated date of this Policy, we may have obtained personal information about you from the following categories of sources:
- From you and your device, for example, through your use of the website when you send us an email, when you create an account, or otherwise visit, contact or communicate with us
- From our affiliates
- From our vendors
- From advertising networks
- From social networks
- Disclosure of Personal Information
During the 12-month period prior to the last updated date of this Policy, we may have disclosed your personal information to certain categories of third parties, as described below.
We may have disclosed the following categories of personal information about you for the business purposes described above in Section 1 to the following categories of third parties:
Category of Third Party Categories of Personal Information Vendors, consultants and advisors who provide services on our behalf Identifiers; Customer Records Data; Protected Classifications; Online Activity; and Inferences Data analytics providers Identifiers and Online Activity In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this Policy, we may have disclosed personal information about you with the following additional categories of third parties:
Category of Third Party Categories of Personal Information Acquiring/merging entity, in the event of a sale or transfer of all or a portion of our business or assets Identifiers; Protected Classifications; Online Activity; and Inferences Government entities and investigatory bodies, including regulatory agencies and law enforcement Identifiers; Customer Records Data; Protected Classifications; Online Activity; Inferences; and Sensory Information We may disclose personal information for other reasons that we may describe to you from time to time or as permitted by law.
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Sale of Personal Information We do not sell your personal information. This site is meant for adults 21 years of age and older only. We do not knowingly collect personally identifiable information from anyone under 21. Accordingly, we do not sell the personal information of individuals under 21 years of age if we have actual knowledge of the individual’s age.
- Sharing of Personal Information for Cross-context Behavioral Advertising
We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. We may share for cross-context behavioral advertising purposes and may have shared during the 12-month period prior to the last updated date of this Policy the following categories of personal information about you to online advertising services: Identifiers, Commercial Information, Online Activity, and Inferences.
- California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Rights Under the CCPA
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
Correction: You have the right to request that we correct inaccuracies in the personal information we have collected about you. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.
Deletion: You have the right to request that we delete certain personal information we have collected from you subject to certain exceptions under the law. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. In the case of requests submitted online, if we are able to verify your identity (as described below), we may ask you to confirm that you would like your personal information deleted prior to deleting any of your personal information.
Opt-Out of Sale or Sharing: You have the right to opt-out of sale of your personal information or sharing of your personal information for cross-context behavioral advertising. We do not sell your personal information.
How to Submit a Request:
Follow this link to submit a request. You may also submit a request by sending us an email at TobaccoRightsPrivacyStatement@consumerconnectioncenter.com with your first name and a phone number at which we may reach you or by calling 1-800-787-6700. Indicate that you are a California resident making a “California Consumer Privacy Act” inquiry.
To submit a request as an authorized agent on behalf of a consumer, please send us an email at TobaccoRightsPrivacyStatement@consumerconnectioncenter.com with your first name and a phone number at which we may reach you and indicate in the subject line that you are making a CCPA Authorized Agent Request, or call 1-800-787-6700.
Verifying Access, Correction and Deletion Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.
- If you request to access, correct or delete your personal information, we may require you to provide information such as: email and zip code.
- In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Non-Discrimination: We will not discriminate against you if you choose to exercise any of your rights under the CCPA.
Rights Under California’s “Shine the Light” Law
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please contact us at www.tobaccorights.com/contactus/ or by calling us at 1-800-787-6700. Indicate that you are a California resident making a “Shine the Light” inquiry.