This Privacy Notice contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to California residents. This Privacy Notice supplements the Graff Privacy Notice. It also contains disclosures required by Nevada law.
California Privacy Rights
Personal Information We Collect. In the preceding 12 months, we collected the following categories of personal information about California consumers.
|Categories of Personal Information||Disclosed for business purposes to the following categories of third parties:||Sold to following categories of third parties:|
|Personal and online identifiers (such as first and last name, email address, or unique online identifiers)||All categories listed below.||All categories listed below.|
|Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)||All categories listed below.||All categories listed below.|
|Characteristics of protected classifications under California or federal law (such as gender)||All categories listed below.||All categories listed below.|
|Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered)||All categories listed below.||All categories listed below.|
|Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)||All categories listed below.||All categories listed below.|
|Biometric information (such as call recordings)||All categories listed below.||All categories listed below.|
|Geolocation information||All categories listed below.||All categories listed below.|
|Professional or employment-related information||All categories listed below.||All categories listed below.|
|Inferences drawn from the above information about your predicted characteristics and preferences||All categories listed below.||All categories listed below.|
|Other information about you that is linked to the personal information above||All categories listed below.||All categories listed below.|
Categories of Sources. We collect personal information from the following categories of sources:
· Advertising networks;
· Data analytics providers;
· Social networks; and
· Service providers.
Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Notice. These commercial and business purposes include, without limitation:
· Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
· Our business purposes as identified in the CCPA, which include:
o Auditing related to our interactions with you;
o Legal compliance;
o Detecting and protecting against security incidents, fraud, and illegal activity;
o Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
o Internal research for technological improvement;
o Internal operations;
o Activities to maintain and improve our services; and
o Other one-time uses.
Recipients of California Personal Information. We “sell” the categories of personal information designated above to the categories of third parties listed below. As is common with companies with an online presence, we work with third parties to serve targeted advertising and engage in activities related to digital advertising like analytics and reporting. These companies may collect personal information through our properties, as defined by the CCPA, such as IP addresses and digital identifiers in order to provide you with relevant ads. These activities may be considered a “sale” under the broad definition of the CCPA.
· Advertising/marketing companies;
· Advertising networks; and
· Social networks.
We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:
· Service providers;
· Advertising networks;
· Data analytics providers; and
· Social networks.
Your Rights Regarding Personal Information. California residents have certain rights with respect to their personal information. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
· The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
· The right to request that we delete the personal information we have collected from you.
· The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
· The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
· By phone at 1-800-982-8133
· Online at firstname.lastname@example.org
Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your full name and email address to verify your request.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. If you do so, we may require you to provide the authorized agent written permission to make a request on your behalf and, for access and deletion requests, we may require you to verify your own identity directly with us.
Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
Nevada Privacy Rights
Although we do not currently conduct sales of personal information, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future.
To exercise this right, please contact us by email at email@example.com.
Contact for More Information
For questions or concerns about Graff’s privacy notice or practices, please contact us by using the information below.
· Email: firstname.lastname@example.org
· Postal mail: 28-29 Albemarle Street, London, W1S 4JA
Effective date: August 2020