Consumer Safety Technology Privacy Notice for California Residents

Effective November 2022

EXERCISE YOUR RIGHTS

CST provides this Privacy Notice for California Residents (this “California Notice”) to supplement the information and disclosures contained in our General Privacy Notice. This California Notice applies to all customers, website visitors, and others who reside in the State of California. We adopt this California Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), which is effective January 1, 2020, as amended by the California Privacy Rights Act, which is effective January 1, 2023. Any terms defined in the CCPA have the same meaning when used in this California Notice.

California residents have the right to request that a business disclose what personal information it collects, uses, discloses, and sells, as well as other rights described below. The CCPA allows California residents to request that a business that collects consumers’ personal information disclose to consumers the categories of personal information that the business collects from consumers, the business or commercial purposes for collecting the information, and the categories of third parties with which the information is shared. California residents also have the right to submit a “Consumer Request” to a business to request access in a portable and readily usable form (if technologically feasible) to the specific pieces and categories of personal information that the business has collected about the consumer, the business purpose for collecting, sharing or selling their personal information, the categories of third parties to whom the business discloses personal information, to request the deletion or correction of information under certain circumstances, among other rights described below. Also, consumers have the right not to receive discriminatory treatment by a business for the exercise of the privacy rights conferred by the CCPA.

Sale of Personal Information

We do not sell your personal information to third parties.

Collection of Personal Information

We collect personal information about consumers and in some cases allow third parties to collect personal information on our behalf, such as IP address. In the last twelve months, we have collected the following categories of personal information both online and offline for the business purpose(s) identified below (some categories may overlap):

Sharing of Personal Information

In the last twelve months, we have shared the following categories of personal information with the following categories of third parties (some categories may overlap):

Category of Information	Shared?	Categories of Third Parties
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	YES	Service Centers Probation Officers Monitoring Authorities The State of California Courts Parties that you authorize Our affiliate companies Payment processors Law firms and attorneys Criminal background/history providers Debt collectors Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers As part of a legal process
Any categories of personal information described in subdivision (e) of Section 1798.80 (the California Customer Records statute).	YES	Service Centers Probation Officers Monitoring Authorities The State of California Courts Parties that you authorize Our affiliate companies Payment processors Law firms and attorneys Criminal background/history providers Debt collectors Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers As part of a legal process
Characteristics of protected classifications under California or federal law.	NO	We do not collect this information. This type of information may be received incidental to other information you provide to us for business purposes, such as if you provide a copy of a drivers’ license. However, we do not use this information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	Service Centers Probation Officers Monitoring Authorities The State of California Courts Parties that you authorize Our affiliate companies Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers
Biometric information.	NO	We do not collect this information. This type of information may be received incidental to other information you provide to us for business purposes, such as if you provide a copy of a drivers’ license. However, we do not use this information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	YES	Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers
Geolocation data.	YES	Probation officers Monitoring authorities The State of California Courts Parties that you authorize As part of a legal process
Audio, electronic, visual, thermal, olfactory, or similar information.	YES	Service Centers Probation Officers Monitoring Authorities The State of California Courts Parties that you authorize As part of a legal process
Professional or employment-related information.	YES	Probation Officers Monitoring Authorities The State of California Courts Parties that you authorize As part of a legal process Our affiliate companies Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	YES	Courts Parties that you authorize As part of a legal process Our affiliate companies Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers
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, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	Our affiliated entities Other service providers to assist us with our business operations, including shipping companies, auditors, and marketing, advertising, and communications service providers
Sensitive personal information.	YES	Probation officers Monitoring authorities The State of California Courts Parties that you authorize As part of a legal process

We may combine your personal information that you provide us through our website with other information we have received from you, whether online or offline, or from other sources such as from our service providers. For more information, please see our General Privacy Notice.

Data Retention Policy

Unless otherwise required by law, we will retain your personal information to the extent necessary to fulfill the purpose for which that personal information was collected. Please note that We may be required to retain your personal information for a reasonably longer period of time to the extent necessary to comply with regulatory or legal obligations, resolve disputes, enforce our agreements or for any other business purpose in accordance with applicable laws.

We generally retain your personal information based on the following criteria:

1. The length of time we are required to store your personal information based on State and/or Federal law;
2. The period by which we are required to purge your personal information in accordance with State and/or Federal law;
3. Whether the purpose for which the personal information was collected has been fulfilled;
4. Whether the personal information is no longer required for analytics or performance purposes;
5. Whether we have received a valid deletion request from a California resident under applicable law.

Consumer Rights

If you are a California resident, you may exercise certain privacy rights related to your personal information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law.

You may submit your request in person, using our toll-free number or via online form. Please see Contact Information below.

1. The Right to Know, Access, Rectify, and/or Delete Personal Information

Where the CCPA/CPRA applies to the services we provide, you may have the right to know, access, correct, opt-out of the sharing and/or delete personal information about you which we have collected.

The Right to Know/Access: You have the right to know about the information contained in this Notice and our General Privacy Notice, and to request access to a copy of the personal information that we have collected about you directly or indirectly, including personal information collected by a service provider or contractor on our behalf. Generally, you may be able to access your personal information through your online user account if you have created one.

You also have the right to know what personal information the business has collected about you, including:

• The categories of personal information;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting, selling or sharing personal information;
• The categories of third parties to whom the business discloses personal information; and,
• The specific pieces of personal information the business has collected about the consumer.

The Right to Correct: You have the right to correct inaccurate personal information that we maintain about you. You may access your account through our websites or mobile app and update your personal information. For personal information that cannot be changed via your account or as an alternative means of updating your personal information, you may contact us to request the change – please see Contact Information below. We will use commercially reasonable efforts to honor your requests within the limits defined by applicable law.

The Right to Delete: You have the right to request that we delete the personal information we have collected about you, subject to certain limited exceptions. For example, we may retain an archived copy of your records consistent with applicable law, to continue to provide our services to you, or for other legitimate business purposes.

2. The Right to Opt-out of the Sale or Sharing of Personal Information

You have a right to opt-out of the sale or sharing of your personal information by us, except in certain circumstances as permitted by law. For example, personal information is not “shared” if done in order to comply with applicable laws, a court order or a subpoena.

• We do not sell your personal information for monetary or other valuable consideration.
• We do not sell any de-identified personal information. We may de-identify your personal information for internal use only.
• We did not share the personal information of 100,000 or more California consumers or households for the purposes of “cross-context behavioral advertising” in the last twelve months. Cross-context behavioral advertising is “the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.”

3. The Right to Limit the Use of Sensitive Personal Information

We collect, process or disclose sensitive personal information solely to the extent required to comply with legal requirements and as necessary to perform the services or provide the goods that you reasonably expect from us. We do not collect sensitive person information to infer characteristics about you or for the purposes of cross-context behavioral advertising.

4. The Right to Non-Discrimination

We will not discriminate or retaliate against you for exercising your consumer rights under the CCPA/CPRA, including by (a) denying you goods or services; (b) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; or (c) providing you a different level or quality of goods or services (or suggesting that we will do so). We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if there is a legitimate business purpose such as labor, varying product offerings and other commercial reasons.

This section currently applies to consumers. In 2023, this section may also apply to employees, applicants for employment, and independent contractors.

Opt-Out Signals

If you are using a browser with enabled global privacy controls or opt-out preference signals, you may opt-out of the sale or sharing of your personal information using such signals. This must be initiated through your browser and applies to your specific device and browser used at the time you cast the signal. We will honor such requests in a frictionless manner provided that they are in accordance with applicable laws. For more information on how these privacy controls work, please consult with your internet browser provider.

Processing Your Request

As required or permitted under applicable law, we may take steps to verify your request is not fraudulent before providing personal information to you, deleting personal information, or otherwise processing your request. Such steps may include being asked to verify your ability to control the email address or phone number you have provided to us.

To process your request, you must provide your name, your relationship to the business product, email address, phone number, and state of residence . If we believe we need further information to verify your identity or as necessary to complete your request (in accordance with applicable laws), we may ask you to provide additional information for these purposes. We will review each request carefully and respond accordingly within the timeframe established by the CCPA/CPRA.

Agent Authorization

You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this Notice. Even if you choose to use an agent, as permitted by law, we may require you to confirm you have authorized the agent to act on your behalf or require you to verify your own identity.

Contact Information

If you have questions or comments about this Notice, our privacy policies, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

Toll-Free Phone: 833-989-1425
Mail: Consumer Safety Technology, LLC
Attn: Legal Dept, Privacy
11035 Aurora Ave
Des Moines, IA 50322

Alternatively, you can submit a CCPA/CPRA request using the form below.

How to Submit a Request

To submit a request under the CCPA/CPRA, please call our toll-free number: 833-989-1425 or submit a request here: