ccpa

Privacy Notice for California Consumers

Effective date: December 30, 2019

Brownie Brittle, LLC (“Brownie Brittle”) provide this Privacy Notice for California Consumers (the “CCPA Privacy Notice”) to supplement the information contained in the Brownie Brittle Privacy Policy. This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).

The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”).

Information We Collect

We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, through the mail, and/or over the telephone. More specifically, Brownie Brittle, LLC (“Brownie Brittle”) collects the following categories of Personal Information from its Consumers:

Category Examples of Personal Information Collected
A. Identifiers. A real name, user name, mobile phone number, mobile device ID, postal address, Internet Protocol address, email address.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, address, telephone number, date of birth, gender.
C. Protected classification characteristics under California or federal law. Age, date of birth, gender.
D. Commercial information. None.
E. Biometric information. None.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data. Physical location or movements.
H. Sensory data. None.
I. Professional or employment-related information. None.
J. Education information, as defined by the Family Educational Rights and Privacy Act None.
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics resulting or relating to points acquired and Rewards redeemed.

Personal information does not include deidentified or aggregated consumer information.

Brownie Brittle obtains 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 or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.

 

How We Use Personal Information

We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:

  • To act in accordance with your direction. For example, where you intentionally interact with our program and direct us to share personal information, we use your personal information in accordance with your direction and share your personal information you provide to us by registering and earning rewards with all our participating brands. In addition, by uploading receipts, participating in Challenges or taking Surveys offered by a Partner, you are using us to intentionally interact with our participating brands who provide points in our Program.
  • To fulfill or meet the purpose for which you provided the information. For example, if you provide your personal information to become a member, scan receipts, [make a payment] or redeem a reward, we will use that information to provide you member benefits or process your transaction.
  • To contact you and to inform you about products, services, promotions, special offers, and/or events that may interest you.
  • To inform you about rewards you have redeemed products and services you have purchased from us.
  • To create, maintain, customize, and secure your account with us.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • If you provide your information in the context of an employment application or your employment, we will use your information to serve those purposes.
  • To personalize your App or Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, mobile applications, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our App or Website, products and services, databases and other technology assets, and business, and to prevent fraud.
  • For research, analysis, and business development, including to develop and improve our Website, 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 subsequently agreed to by you.
  • 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 about our Consumers is among the assets transferred.

 

How We Share Personal Information

Brownie Brittle, LLC (“Brownie Brittle”) may disclose your Personal Information to a third party for a business purpose, including to our service providers.

We share your personal information with the following categories of third parties:

  • Service providers.
  • Third parties with whom you direct us to share your personal information, including our participating brands.

 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Brownie Brittle, LLC (“Brownie Brittle”) disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.

 

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Third parties with whom you direct us to share your personal information, including our participating brands.

 

Sales of Personal Information

In the preceding twelve (12) months, Brownie Brittle, LLC (“Brownie Brittle”) has not sold personal information.

Your Consumer Rights and Choices

The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Brownie Brittle, LLC (“Brownie Brittle”) disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you.
  • If we disclosed your Personal Information for a business purpose, a list disclosing the disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that Brownie Brittle, LLC (“Brownie Brittle”) delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, 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, 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a CCPA Privacy Request here on our Request Personal Data page or you may Manage Your Own Personal Data once you have logged into your account.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • 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.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us:

by email: info@browniebrittle.com

by writing to us at:
Brownie Brittle
PO Box 740223
Boynton Beach, FL 33474

Changes to Our CCPA Privacy Notice

If you have any questions or comments about this notice, the ways in which we collect and use your information described above [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

by email: info@browniebrittle.com

by writing to us at:
Brownie Brittle
PO Box 740223
Boynton Beach, FL 33474

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