Donaghy Sales, LLC Privacy Policy and CCPA Privacy Notice for California Consumers Effective Date: January 1, 2020 Last Modified on: December 31, 2019 Introduction Donaghy Sales, LLC and all related and affiliated companies, including but not limited to Donaghy Sales Promotions, LLC (collectively, “Donaghy Sales”, the “Company,” “we,”, “us” or “our”) respects your privacy and is committed to protecting it. We collect data: About users of our Website. About individuals who contact us online, by telephone or electronic means, or in person. About individuals who visit our facilities or operations; about individuals who attend events organized or hosted by us. About our customers or prospective customers (where these are natural persons) or their employees, agents, and representatives; About others who express an interest in us or with whom we carry on business Collectively, these individuals about whom we collect data are referred to as “you” and “your” in this Privacy Policy. This policy describes the types of information we may collect from you, or that you may provide when you visit our website http://donaghysales.com (“Website”), or otherwise contact us, and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect: On our Website. In email, text, and other electronic messages between you and us, including between you and our Website. Through or as a result of your entry upon any of our facilities, or in connection with our operations, or attendance at an event organized or hosted by us. As a result of any sales, purchases, or other transactions made through us. Any paper submitted by you to us offline. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our website or submit information to us. By accessing or using our Website and/or submitting information to us, you agree with this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website and/or provision of information to us after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Information We Collect We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). In particular, the Company collects and has collected from its consumers within the last twelve (12) months the following categories of Personal Information: Personal identifiers you provide when you provide information for orders, reservations, or registration on our Website, including your first and last name, alias, business name, business address, email address, telephone number, account number, online identifier, or any personal identifiers you provide to us when communicating with us. Transaction information you provide when you make a purchase from us, such as your first and last name, alias, address, telephone number, email address, and payment or financial information. Financial information you provide for payment information when you make a purchase from the Company, including through our Website, such as your bank account number, debit card number, and/or credit card number. • Records of commercial information such as your current and historical point-of-sale transactions and product purchases from us. Single-session internet connectivity, usage, and activity information about your use, and the use by any person(s) you authorize, of our Website, including the content you view, browser device and type, unique device identifier and/or Internet Protocol (IP) address, and information about your interaction with our Website. Location information, including geolocation information provided through our Website’ server logs and through Google analytics for our Website by your device interacting with our website, or associated with your Internet Protocol (IP) address, where we are permitted by law to process this information. Sensory data observed on general business security video surveillance at our facilities and operations and within our property for the security and safety of our employees, customers, operations, assets, resources, and communities. Personal Information does not include: Publicly available information from government records. Deidentified or aggregated consumer information. Information excluded from the CCPA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. How We Collect Your Information The Company obtains the categories of Personal Information listed above from the following categories of sources: Directly from you. We collect information you provide to us when you inquire about our goods or services, register with us, request or purchase products, through the billing and contact information you provide to us, or when you communicate or otherwise interact with us through telephone, email or other electronic communication, through the use of our Website, through the mail or in person. Indirectly from you. We collect information from you, your household, or devices associated with you or your household through your use and actions on our Website, first-party session cookies on the Website, and third-party analytics for the Website, as well as publicly available sources of information. We do not use any persistent cookies on our Website. Use of Personal Information We may use or disclose the Personal Information we collect for one or more of the following purposes: To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote, or ask a question about our products or services, or communicate with us through email, our Website, or by telephone, we will use that Personal Information to respond to your inquiry and communicate with you. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders by you or process your requests. To have a means of communicating with you about transactions with us and send you information or request feedback about features on our Website or changes to our policies. To send you offers and promotions for our products and services. To provide, support, personalize, and develop our Website, products, and services. To process your requests, purchases, transactions, and payments and prevent transactional fraud. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. To personalize your Website experience and to deliver content and product and service offerings relevant to your interests (with your consent, where required by law). To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business. For testing, research, analysis, and product 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 as otherwise set forth in the CCPA. The Company will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing Personal Information The Company does not disclose, share, or sell your personal information to any third parties for any monetary or commercial benefit, and has not disclosed, shared, or sold your personal information in the past 12 months, for any monetary or commercial benefit. The Company only discloses your information for a business purpose to service providers we utilize to provide goods and services for you and for marketing and web hosting in order to provide you with targeted communications and services that are tailored to your preferences. CCPA Privacy Notice—The Rights of California Consumers Under the California Consumer Privacy Act (“CCPA”) The California Consumer Privacy Act of 2018 (CCPA) provides California residents who are “consumers,” as defined in the CCPA, with specific rights regarding their Personal Information. This section of this Policy describes the rights of “consumers,” as defined in the CCPA, and explains how California consumers can exercise those rights (“CCPA Privacy Notice”). Any terms defined in the CCPA have the same meaning when used in this CCPA Privacy Notice. Consumers with disabilities may access this CCPA Privacy Notice in an alternative format by contacting The Company through any one of the methods set forth below. Right to Request Disclosure About the Personal Information Collected About You Consumers, as defined in the CCPA, have the right to request that The Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we have received and verified your request, 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, if any. The specific pieces of Personal Information we collected about you (also called a data portability request). If we disclosed your Personal Information for a business purpose, a separate list identifying disclosures for a business purpose and the Personal Information categories that each category of recipient received. However, The Company will not at any time in response to a request disclose a consumer’s financial account number, an account password, or security questions and answers. The Company is not required to retain any Personal Information collected for a single, one-time transaction, if the information is not regularly retained by The Company, or re-identify any anonymous or de-identified information, in order to disclose that information to you. Deletion Request Rights Consumers, as defined in the CCPA, have the right to request that The Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we have received and verified your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request 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. Debug products to identify and repair errors that impair existing intended functionality. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 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 and Deletion Rights To exercise your Access and Deletion Rights, you will need to submit a verifiable consumer request so that The Company is able to corroborate your identity and provide your information to you. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Calling us at 1-800-675-4544 Emailing us at lvaldez@donaghysales.com Mailing us at: Donaghy Sales, LLC Attn: Lisa Valdez, HR Manager 2363 S. Cedar Ave. Fresno, CA 93725 Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. 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. 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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will 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. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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. Personal Information Sales Opt-Out and Opt-In Rights If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We will not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer younger than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by any of the methods set forth above. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may opt back in to Personal Information sales at any time. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Our Website May Have Third Party Links Our Website may have links to third-party content. We do not control that content or the third party’s privacy practices. We encourage you to read their privacy policies to understand how they use your information. Changes to Our Privacy Notice The Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Website and update the Policy’s effective date. Your continued use of our Website and/or submitting information to us following the posting of changes constitutes your acceptance of such changes. Last Modified: December 31, 2019 Contact Information If you have any questions or comments about this Policy, the ways in which the Company collects and uses your information, or wish to exercise your rights under California law, please contact us at: Phone: 1-800-675-4544 Email: lvaldez@donaghysales.com Postal Address: Donaghy Sales, LLC Attn: Lisa Valdez, HR Manager 2363 S. Cedar Ave. Fresno, CA 93725 Privacy PolicySite Map © 2020 Donaghy Sales All rights reserved