CCPA Privacy Notice

This CCPA privacy notice (“Notice”) supplements the information contained in Northerner’s general Privacy Notice and applies solely to California consumers. 

We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).  Any terms used in this Notice but not defined shall have the meaning ascribed to them in the CCPA.

This Notice describes our practices regarding the collection, use and disclosure of the personal information of California consumers both online and offline.  For the purpose of this Notice, we may refer to our website, including use on mobile devices, tablets, personal computers, and any other devices that connect to the internet that link to this Privacy Notice.

If you have any questions or concerns about our privacy policies and practices, please contact us at [email protected].

  1. What Information is Covered by this Notice?

This Notice relates to our collection, use, and disclosure of California consumers’ personal information. “Personal information,” as used herein, generally means information that relates to you or your household.  The chart below identifies the categories of personal information we have collected about California consumers in the previous 12 months. 

  • Identifiers such as name, date of birth, address, telephone number, payment details including bank account number, credit card number, debit card number or other similar identifiers.
  • Information such as a unique online identifier, Internet Protocol address, email address, or other similar identifiers.
  • Characteristics of protected classifications under California or federal law such as gender, marital status and certain demographic data.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation data.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, browser type and version, time zone setting and location, browser plug-in types and versions and operating system and platform, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Audio information, including call recordings of conversations with Customer Care.
  • Professional or employment-related information.
  • Education information.
  • Information included in feedback and survey responses, which may include personal information relating to your lifestyle and usage of our products.
  • Household composition data.
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities, and aptitudes.

  1. What Are the Sources from Which Personal Information is Collected?

We collect your personal information through direct interactions with you, for example when you submit an order to us, create an account, complete one of our surveys or contact our customer services centre.  We also collect your personal information using automated technologies when you interact with our website. We may also collect your personal information from third parties such as analytics providers, advertising networks and data brokers or aggregators.

 

  1. How Do We Use Personal Information?

We may use your personal information for a variety of business or commercial purposes. For a detailed list on how we may use personal information, please see section 3, “Why do we process personal information” in our general Privacy Notice.


  1. Who Do We Share Personal Information With?

 

Personal Information Disclosed.  We have disclosed the following categories of personal information in the preceding 12 months to other companies within our group and some third-party business partners, including payment processing providers, logistic suppliers, and analysis and marketing partners.

  • Identifiers such as name, date of birth, address, telephone number, payment details including bank account number, credit card number, debit card number or other similar identifiers.
  • Information such as a unique online identifier, Internet Protocol address, email address, or other similar identifiers.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Geolocation data.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, browser type and version, time zone setting and location, browser plug-in types and versions and operating system and platform, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities, and aptitudes.

Personal Information Sold.  We have not sold your personal information to anyone in the preceding 12 months.  We do not collect nor sell personal information of minors under 16 years of age.


  1. Financial Incentive Programs

We provide financial incentives to individuals who register an account on our website, sign up to receive communications from us, or response to a survey. The information we request may include email address, phone number, name, birthday, product preferences or other information that allows us to tailor our communications. Participation is always voluntary. As financial incentive, we provide personalized coupons, promotions, and other discounts or offers, which helps us establish a relationship with our customers. The value of this personal information data varies based on the offer provided, the amount purchased for using that offer, and value of future offers the customer receives from us and uses to make purchases. The personal information also generates value for us in our internal data analytics solutions, primarily based on anonymized customer data, where we strive to understand what matters to our customers in order to improve our business and deliver relevant value to our customers.


  1. Your CCPA Rights

 

Subject to certain exceptions, the CCPA affords California consumers the following rights:

  1. Request to Know. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you any or all of the following, as requested by you:
  • The specific pieces of personal information we collected about you.
  • The categories of personal information we collected about you.
  • The categories of sources from which we collect personal information about you.
  • The categories of personal information that we have disclosed about you for a business purpose.
  • The categories of third parties to whom we have disclosed your personal information for a business purpose.
  • Our business or commercial purpose for collecting personal information.

 

  1. Request to Delete. You have the right to request that we 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, we will delete (and direct our service providers to delete, as applicable) your personal information from our records, unless an exception applies.

 

  1. Request to Opt-Out of the Sale of Personal Information. California consumers have the right to opt out of the sale of their personal information by a business.  We do not sell any personal information.

 

  1. No Discrimination. You have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.


  1. How to Exercise Your CCPA Rights

Below are instructions for how you can exercise your rights under the CCPA.

 

  1. Submitting a Request to Know. You may submit a Request to Know by emailing us at [email protected] or by calling us at +1-844-516-4699. 

 

  1. Submitting a Request to Delete. You may submit a Request to Delete by emailing us at [email protected] or by calling us at +1-844-516-4699. In connection with any personal information we may collect through cookies, for your deletion request to be effective, you must also delete cookies using each device and browser you use in connection with our website.  To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

 

 

  1. Verification Methods. Once you submit a request, we will verify that you are the consumer to which the request pertains by matching the identifying information provided by you (g., name, email address, account-related information) to the information we maintain.  Depending on the type of request you submit, we will attempt to match either two or three of the data points you provided.  If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request. 

 

You can select an “authorized agent” to submit requests on your behalf.  We will require the authorized agent to have a written authorization confirming that authority.  We may also require you to verify your own identity directly with us.  Once your authorized agent is verified, they may submit a request in the typical way described above.


  1. California “Shine the Light” Disclosure

California residents have the right under certain circumstances to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared.  To make such a request, please send an email to [email protected] and please include the phrase “California Shine the Light Privacy Request” in the subject line, along with your name, address and email address.  We will respond to you within thirty days of receiving such a request.


  1. California “Do Not Track” Disclosure.

While we strive to offer you choices when you use our website and mobile application, we do not promise that we will be able to receive or honor web browser Do Not Track signals.


  1. Alternate Format of CCPA Notice

If you have a disability that prevents or limits your ability to access this Notice, please email us at [email protected].  We will work with you to provide this notice in an alternative format.


  1. Changes to this Notice

We reserve the right to make changes to this Notice. Any such changes will be published on the Site. We therefore encourage you to periodically review this Notice for any changes.

The latest update was made on 19 January 2021.