Privacy Notice for California Residents
This Privacy Notice for California Residents (the “Notice”) supplements the information contained in our Privacy Policy (www.sojoindustries.com/privacy) and applies only if you reside in the State of California (you are a “California Consumer”).
For purposes of this Notice “Sell,” “Selling,” “Sale,” or “Sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to another business or a third party for monetary or other valuable consideration.
“Share”, “Shared,” or “Sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Information to a third party for Cross-context Behavioral Advertising, whether or not for monetary or other valuable consideration.
“Cross-context Behavioral Advertising” means the targeting of advertising to a consumer based on that consumer’s Personal Information obtained from activity across businesses or distinctly-branded websites, applications, or services, other than the business or distinctly-branded website, application, or service with which the consumer intentionally interacts. (In other words, if we send you an ad based solely on your interaction with us or our Services, this is not Cross-context Behavioral Advertising.)
“Sensitive Personal Information” means Personal Information that is not publicly available and reveals one or more of the following:
- A consumer’s Social Security, driver’s license, state identification card, or passport number;
- A consumer’s account log-in, financial account, debit card or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
- A consumer’s precise geolocation;
- A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
- The contents of a consumer’s mail, email, and text messages unless we are the intended recipient of the communication;
- A consumer’s genetic or biometric data;
- A consumer’s neural data; or
- Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.
“Verifiable Request” means that the identifying information provided by a consumer in connection with a request matches the Personal Information of the consumer already maintained by us . Identifying information includes:
- Name;
- Business email address; and
- Employer
Information We Collect
In the past twelve (12) months, Sojo has collected the following categories of Personal Information from California residents:
- Identifiers, like first and last name, email address, IP address, and device ID;
- Professional or employment-related information, like business email address and the postal address of the company at which a California resident works;
- Certain internet activity, like the pages of our website viewed during a visit or the features of the Sojo mobile app used; and
- Information contained in any image, photograph or profile submitted to us
Additionally, in the past twelve (12) months, Sojo has collected the following categories of Sensitive Personal Information from California residents:
- Precise geolocation.
Sojo obtains this Personal Information from the following types of sources:
- Directly from you. For example, from forms you complete or products and services that you purchase; and
- Indirectly from you. For example, from information automatically sent by your web browser or from analyzing data about your actions on our website.
Use of Personal Information
Sojo may use or disclose the Personal Information we collect for one or more of the following “Business Purpose(s):”
- To fulfill or meet the reason you provided the information;
- To provide our website, online services , or mobile app;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- To respond to your requests under the California Consumer Privacy Act of 2018 (the “CCPA”), as amended;
- For any other purpose described to you when we collect your Personal Information; and
- For any other acceptable purposes as set forth in the CCPA.
Additionally, Sojo may use or disclose the Sensitive Personal Information we collect for one or more of the following “Business Purpose(s):”
- To fulfill or meet the reason you provided the information;
- To provide our website, online services, or mobile app;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- To respond to your requests under the California Consumer Privacy Act of 2018 (the “CCPA”), as amended;
- For any other purpose described to you when we collect your Sensitive Personal Information; and
- For any other acceptable purposes as set forth in the CCPA.
To the extent that we generate any de-identified data sets based on the Personal Information that we collect or receive through the Services, we will never re-identify any such de-identified Personal Information.
Unless we notify you otherwise, we will not collect additional categories of Personal Information, nor use the Personal Information we collect for any other materially different, unrelated, or incompatible purposes.
Retention of Personal Information
We retain each category of your Personal Information for no longer than is reasonably necessary for one or more Business Purposes, subject to your right to request we delete your Personal Information. Due to the nature of the services, it is not possible to predict the length of time that we intend to retain your Personal Information. Instead, we use the following criteria to determine whether it remains reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s): we retain data (including potentially your Personal Data) for as long as required by the U.S. FDA under Section 204 of the Food Safety Modernization Act, unless a customer ceases using our Services, in which case we may destroy data at that time.
When we determine that it is no longer reasonably necessary to retain your Personal Information for one or more disclosed Business Purpose(s) based on the above criteria, we will delete your Personal Information.
Disclosure of Personal Information
Sojo may disclose Personal Information to our “service providers”, to our “contractors”, and to “third parties” (each as defined by the CCPA) for a Business Purpose. When we disclose Personal Information for a Business Purpose, we enter into an agreement with the receiving party that describes the purpose for sharing the Personal Information, and that requires the receiving party to keep that Personal Information confidential. In the case of disclosures to our “service providers,” our “service providers” are obligated not to use the Personal Information for any purpose other than performing the services according to their agreement with us. In the case of our “contractors”, our “contractors’ are obligated not to use the Personal Information for any purpose unrelated to the business purpose for which we’ve engaged them.
We may disclose your Personal Information with the following categories of entities: “service providers” and “contractors”.
In the past twelve (12) months, Sojo has not Sold or Shared any Personal Information about its California Consumers.
Your Rights and Choices
If you are a California Consumer, you may request information about our collection, use, disclosure and Sale of your Personal Information over the past twelve (12) months, whether or not it was collected electronically. If you submit a Verifiable Request, we will provide you with information regarding:
- the categories of Personal Information we have collected about you; the categories of sources from which your Personal Information was collected; our Business Purpose for collecting, Selling, or Sharing your Personal Information; the categories of third parties with whom we disclose that Personal Information; and the specific pieces of Personal Information we collected about you; and
- if we Sold, Shared, or disclosed your Personal Information for a Business Purpose: what categories of Personal Information we Sold or Shared, and to which categories of recipients we Sold or Shared it; and what categories of Personal Information we disclosed for a Business Purpose, and to which categories of recipients we disclosed it to.
You also have the right to request a copy of your Personal Information, and/or to request that we transmit your Personal Information to another entity. To the extent technically feasible, we will comply with your request and provide and/or transmit your Personal Information in a structured, commonly used, machine-readable format.
You also have the right to request that we delete any of your Personal Information that we collect or maintain by submitting a Verifiable Request. We may deny your deletion request if retaining your Personal Information is necessary for us or our “service providers” or “contractors” to:
- Complete the transaction for which we collected your Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide goods or services that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Help to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for those purposes;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, 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 that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information; or
- Comply with a legal obligation.
You further have the right to request that we correct any of your Personal Information that is inaccurate by submitting a Verifiable Request. We will correct any inaccurate Personal Information pursuant to your request to the extent possible using commercially reasonable efforts. We may deny your correction request if the Personal Information is accurate. We may also delete your Personal Information instead of correcting it to the extent such deletion would not negatively impact you.
Lastly, you have the right to request that we limit the use and disclosure of Sensitive Personal Information by submitting a Verifiable Request. If you submit such a Verifiable Request, we may continue to use or disclose your Sensitive Personal Information to:
- Complete the transaction for which we collected your Personal Information, provide goods or services 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;
- Use in a short-term and transient manner, including, but not limited to, to facilitate non-personalized advertising shown as part of your current interaction with the Services, but not including disclosure to third parties or use outside your current interaction with the Services;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; or
- Make any other uses of that information that are permitted by the CCPA and its implementing regulations.
If you choose to exercise a privacy right under the CCPA, you have the right not to receive discriminatory treatment.
You may submit a Verifiable Request for the information listed above, or exercise any of your rights enumerated under this Notice, by calling us at (888) 873-0537, or by completing a form on our website at https://sojoindustries.com/contact-us. You may also submit a Verifiable Request on behalf of your minor child.
After we receive your Verifiable Request, we will provide to you, in writing and free of charge (unless your request is excessive, repetitive, or manifestly unfounded), the requested information for the 12-month period preceding your request (unless you specifically request disclosure beyond such 12-month period, in which case, we will process your request with respect to Personal Information we have collected during the time period you specify, provided that (a) the earliest date that your request may apply to is January 1, 2022, and (b) processing your request does not require disproportionate effort). You can choose to have this information delivered to you by postal mail, or electronically. We will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. Please note that we are not required to comply with your request for information more than twice in any 12-month period. If applicable, our response will explain the reasons why we cannot comply with your request.
Sojo does not and will not, without first obtaining your consent, Sell or Share Personal Information.
Should you choose to exercise any of the rights enumerated under this Notice, 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; or
- 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, please be aware that it may be a functional necessity for our Services to have Personal Information about you in order to operate, and we may not be able to provide some or all of our Services to you if you direct us to delete your Personal Information.