La Sportiva N.A., Inc. Additional Privacy Rights for California Residents - California Consumer Privacy Act Notice

Last modified 16 September 2020. Effective immediately.

This California Consumer Privacy Act (“CCPA”) provides California residents with additional privacy rights. This California Consumer Privacy Act Notice (“CCPA Notice”) incorporates and supplements all of the information contained in La Sportiva N.A., Inc.’s (“LNA”) current Privacy Policy (the “Privacy Policy”) and applies solely to residents of the State of California ("consumers" or "you"). We adopt this notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice. All terms defined in the current Privacy Policy also have the same meaning when used in this Notice.

Information We Collect

Our Privacy Policy defines and describes “personal information,” which also applies in this CCPA Notice. We collect personal information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. The term “personal information” does not include (a) publicly available information, including from government records; (b) anonymous, deidentified, or aggregated consumer information; and (c) any other information excluded from the any applicable state or federal law, including but not limited to the CCPA. In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

CATEGORY

EXAMPLES

COLLECTED

A. Identifiers

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

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

We obtain the categories of personal information listed above from various sources, including directly from you (e.g., from forms you complete or products and services you purchase), indirectly from you, (e.g., from observing your actions on our Website), and from our third-party vendors and analytics.

Use of Personal Information We Collect

Information regarding our collection, use, and disclosure of personal information is described in our Privacy Policy. Our Privacy Policy describes the categories of personal information we collect, how we collect personal information, the purposes for which your personal information is used, and the categories of third parties with whom we share your personal information. We do not sell, will not sell, and, within the preceding 12 months, have not sold personal information to any third parties. We use cookies in certain circumstances, and information describing our use of cookies is available in our Privacy Policy.

Sharing Personal Information

We may disclose your personal information to third parties for business purposes and information describing such disclosure is in our Privacy Policy. When we disclose personal information for a business purpose, we usually enter into agreements with those third parties that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the categories of personal information that we collect and have identified in the above chart for a business purpose.

Your Rights Under the CCPA

The CCPA provides California residents with the following rights regarding their personal information.

1. Access to Specific Information and Data Portability Rights. You have the right to submit a verifiable request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. The type of information that the CCPA allows you to request are the following: (a) The categories of personal information we collected about you; (b) The categories of sources for the personal information we collected about you; (c) Our business or commercial purpose for collecting or selling that personal information; (d) The categories of third parties with whom we share that personal information; (e) The specific pieces of personal information we collected about you (also called a “data portability request”); and (f) If we sold or disclosed your personal information for a business purpose, two separate lists disclosing (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Once we receive and confirm your verifiable consumer request (see 3. Exercising Access, Data Portability, and Deletion Rights below), we will disclose the information you requested as provided below (see 4. Response Timing and Format).

2. Deletion Request Rights. You have the right to request that we delete your personal information that we collected and retained under certain circumstances. Once we receive and confirm your verifiable consumer request, we will delete (and ask our service providers to delete) your personal information from our records, unless one or more of the exceptions below apply.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (a) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (b) Maintain the functionality or security of our systems, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) Debug products to identify and repair errors that impair existing intended functionality; (d) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (e) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (f) 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; (g) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) Comply with a legal obligation; or (j) Make other internal and lawful uses of that information that are compatible with the context in which you provided it. If we cannot grant your deletion request, we will specify the basis for denial.

3. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

To ensure that your personal information is permanently deleted, you should also delete our cookies from your browser.

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.

A verifiable consumer request must (a) provide sufficient information that allows us to reasonably verify your identity and confirm that you are the person about whom we collected personal information and (b) 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, if you have a password-protected account with us, we may verify your identity through our existing authentication practices for your 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.

You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission signed by you to make a request on your behalf, and your authorized agent additionally is able to verify their identity with us. If you would like to designate an agent for purposes of making a request under the CCPA, your agent must register as such with the California Secretary of State and submit a copy of this registration along with your verified consumer request. Please have your authorized agent follow the instructions above to make a request, and additionally mail your written declaration authorizing the agent to act on your behalf, certified by California notary public, to: CCPA Request, Authorized Agent, La Sportiva N.A., Inc. 3850 Frontier Ave., Ste. 100, Boulder, CO 80301 USA.

Should you need access to this policy in an alternative format due to a disability, please contact us through the methods provided above. A PDF version of this CCPA Notice may be downloaded here.

4. Response Timing and Format. When you contact us, we will confirm receipt of your request within ten days of receiving the request. We endeavor to respond to verifiable consumer requests as soon as we can, which is usually within forty-five (45) days of our receipt of the request. If we require more time (up to 90 days), 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 our receipt of the verifiable consumer request. 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 usually in screen shot or pdf format.

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.

5. Opt-Out of Sale of Personal Information. You have the right, at any time to direct a business that sells personal information about you to third parties not to sell your personal information (the "right to opt-out"). Currently, we do not sell the personal information of consumers of any age, however, the meaning of “sell” under the CCPA is broadly defined and can include sharing your information for any economic benefit. We share your information with service providers and other authorized third parties as described in our Privacy Policy. To the extent that any such third party is not considered a service provider under the CCPA or the CCPA is interpreted in a way that any action of ours is deemed to be a “sale”, is “selling”, or otherwise deriving an economic benefit from the sharing of your personal information as described in our Privacy Policy, and to the extent that you wish us not to share such information, please submit your request to us by either:

To ensure that your personal information is permanently deleted, you should also delete our cookies from your browser.

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 change your mind and opt back in to personal information sales at any time by accessing sportiva.com and agreeing to our Terms of Use and Privacy Policy

6. Non-Discrimination. We do not discriminate against California residents for exercising any of their rights afforded by the CCPA.

7. 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 send an email to [email protected] or write us at: La Sportiva N.A., Inc. Attn: Customer Service 3850 Frontier Ave., Suite 100 Boulder, CO 80301

Information Security, Integrity, and Retention

We take reasonable precautions, including the use of physical, electronic, and procedural safeguards, to protect your personal information as described in our Privacy Policy. It is important that you also take precautions to protect against unauthorized access to your LNA, account credentials, and computers or other devices. If you feel that the security of your LNA account or personal information has been compromised, please immediately contact us at: [email protected]. Please be aware that, despite our efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

Changes to the CCPA Notice

LNA reserves the right to amend the Privacy Policy and/or this CCPA Notice at our discretion and at any time. When we make changes to the Privacy Policy and/or the CCPA Notice, we will post the updated notice on the Website and update the notice's effective date. Please check our Websites regularly to see if this Privacy Policy has changed. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. If you do not agree to the revised Privacy Policy and/or CCPA Notice, please refrain from using our products and services and contact us at [email protected] to close any account you may have created.

Contact Information

If you have any questions or comments about this CCPA Notice or our Privacy Policy, or the privacy or security of your personal information as described here and in the Privacy Policy, or wish to exercise your rights under California law, please do not hesitate to contact us at:

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California Consumer Privacy Act Notice