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California Privacy Notice

Effective Date: July 2, 2020

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) and supplements other privacy policies or notices issued by U.S. Expediters, Inc. dba CPAP.com (“Company” “we” “us”). In the event of a conflict between any other Company policy, statement, or notice and this Notice, this Notice will prevail with respect to California Consumers and their rights under the CCPA. 

This Notice describes our collection, use, disclosure, and Sale of California Consumers’ Personal Information (PI), as well as rights California Consumers have under the CCPA. Terms defined in the CCPA that are used in this Notice have the same meanings as in the CCPA. 

Consistent with the CCPA, job applicants, current and former employees, contractors, and subjects of certain business-to-business communications acting in their capacity as representatives of another business are not considered Consumers for the purposes of this Notice or the rights described herein.

In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.

Personal Information that is also considered “Protected Health Information” under applicable law is, when we are acting as a covered entity under such laws, subject to our Notice of Protected Health Information Privacy Policy, which will govern our practices with respect to such information in those circumstances, notwithstanding anything to the contrary under this California Privacy Notice.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect PI about California Consumers as described in the table below.

CategoryExamples of PI CollectedSources of PIPurposes for PI CollectionCategories of Recipients

Identifiers


Name, postal address, Internet Protocol address, email address, phone number, date of birthProvided by Consumer or collected from the Consumer’s interactions with our website or advertisements 

Managing interactions and transactions; 

detecting security incidents and protecting against fraud; 

processing and customizing concurrent Consumer interactions; marketing

Information may be shared with marketing partners

Customer / Individual Records


Name, postal address, telephone number, email address, payment card details, medical information, customer service case notesDirectly from the Consumer at time of purchase or during purchase verification

Managing interactions and transactions; detecting security incidents and protecting against fraud; processing and customizing concurrent Consumer interactions; marketing; verification of purchases by Consumer


Information may be shared with marketing partners
Commercial Information / Purchase Details Customer ID, Transaction date, Purchased Item ID, Item Price, Invoice Total PriceDirectly from the Consumer at time of purchase

Managing interactions and transactions; 

detecting security incidents and protecting against fraud; debugging; processing and customizing concurrent Consumer interactions; internal research and development; quality control; marketing


Information may be shared with marketing partners

Internet Usage Information


Information regarding interactions with our website or advertisementsConsumer interactions with our website and advertisements

Detecting security incidents and protecting against fraud; internal research and development; debugging; quality control; marketing


Information may be shared with marketing partners; ISPs; analytics and other service providers

Sensory Data


Audio recordings of customer service callsCollected from calls made by Consumers to Customer Service

Managing interactions and transactions; 

detecting security incidents and protecting against fraud; 

quality control 


Information may be available to service providers
Inferences from PI CollectedCustomer profiles reflecting preferences and predispositionsData reflecting preferences are inferred from a Consumer’s interactions with our website or advertisementsDetecting security incidents and protecting against fraud; marketingInformation may be shared with marketing partners


In addition, we may collect, use, and disclose your PI as required or permitted by applicable law. We do not treat de-identified data or aggregate consumer information as PI, and we reserve the right to convert, or permit others to convert, your PI into de-identified data or aggregate consumer information. 

We may share your PI with our affiliates, service providers, vendors (including those that facilitate interest-based advertising and other advertising and marketing), and other parties as described in the table above. These parties may use your PI for some or all of the above-listed business purposes, subject to the CCPA’s restrictions and obligations.

We have not “Sold” (as the term “Sale” is defined by the CCPA) Consumer PI in the past year.

CALIFORNIA PRIVACY RIGHTS

Under the CCPA, California Consumers have certain rights which they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify the identity of the requestor and the validity of the request. 

Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI. Accordingly, we will not include such information in response to Consumer requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create an account with us to make a verifiable request, but you may use your account to do so. We will use PI provided in your request to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, use, store, disclose, or otherwise process, and to respond to your California Consumer privacy rights requests. In some cases, particularly with voluminous and/or typically irrelevant data, we may provide you with a summary of your PI and give you the opportunity to elect whether you want us to provide the entire data set. Alternatively, we may direct you on how to access and copy responsive PI yourself. We may charge a reasonable fee or refuse to act upon a request if the request is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may decline to comply with the request, we will give you notice explaining why we made that decision. In the case of a fee, we will provide a cost estimate and the opportunity to accept such fees before charging you for responding to your request.

Your California Consumer privacy rights are described below. To make a request, please email us at compliance@cpap.com or call us at 1-800-356-5221. We will take appropriate steps to confirm the identity of a Consumer making a request for purposes of verifying the authenticity of the request. You may be required to provide certain PI to allow us to verify that you are the Consumer about whom the request is being made. Please promptly respond to any follow-up inquires so that we may confirm your identity. If you request that we provide you with specific pieces of information about you, we will apply the heightened verification standards. An authorized agent may submit a request on behalf of a Consumer if the Consumer has provided the authorized agent with power of attorney in accordance with California law. Alternatively, the agent must (1) present verifiable written authorization from the Consumer that the agent has the Consumer’s permission to submit the request; and (2) independently verify the agent’s own identity with Company.

We may collect, use, and disclose your PI as required or permitted by applicable law. Please note we are not obligated to comply with consumer requests to the extent that doing so would infringe on our, or any other person’s or party’s, rights or conflict with applicable law.

Disclosure Rights

You have the right to request that we disclose your PI that we have collected and are maintaining for the 12-month period prior to the request date. Consumer requests of this nature may be made no more than 2 times in a 12-month period.

The categories of PI we have collected about you.

The categories of sources from which we collected your PI.

The business or commercial purposes for collecting or Selling your PI.

The categories of third parties to whom we have shared your PI.

The specific pieces of PI we have collected about you.

A list of the categories of PI disclosed for a business purpose in the prior 12 months, or a statement that no such disclosure occurred.

A list of the categories of PI Sold about you in the prior 12 months, or that no Sale occurred. If we Sold your PI, we will explain (1) the categories of your PI we have Sold, and (2) the categories of third parties to which we Sold PI.

You have the right to make or obtain a portable copy of your PI that we (1) have collected in the 12 months prior to the request date and (2) currently are maintaining. Please note that we retain PI for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures. To make such a request, please complete this form.

"Do Not Sell" Rights

We do not Sell California Consumer PI as those terms are defined in the CCPA. Some web browsers have options that may be characterized as “do not track” settings, which may or may not affect your settings related to our website. We do not understand them to operate in that manner or to signify a “do not sell” request made by a Consumer. We understand that various parties are developing “do not sell” signals, and we may recognize certain such signals if we conclude such a program is appropriate. 

Deletion Rights

Except to the extent we have a basis for retention under the CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, retaining PI to complete transactions and provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes such as maintaining business records, to comply with law or otherwise cooperate with law enforcement, and to exercise or defend legal claims. Note also that we are not required to delete your PI that we did not collect directly from you. To make such a request, please complete this form.

Non-Discrimination Rights

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. 

California’s “Shine the Light” Law

California Civil Code Section 1798.83 permits California customers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to compliance@cpap.com or write us at: CPAP.com 13235 N. Promenade, Stafford, TX 77477.

Please note that “Shine the Light” rights and CCPA rights are established under different legal regimes and must be exercised separately.

CONTACT US

For more information regarding your California privacy rights, you may contact us at 1-800-356-5221 or email us at compliance@cpap.com. You may also write to us at CPAP.com 13235 N. Promenade, Stafford, TX 77477.

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