LAST REVISED: SEPTEMBER 1, 2023
Company collects 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 (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in the CCPA. This Notice provides you with information on how Company collects, uses, and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights.
Collection and Use of Personal Information
Company recognizes the twelve (12) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Company has collected the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, address, telephone number, credit card number, debit card number, or other financial information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, national origin, citizenship, marital status, 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).
D. Commercial information.
, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio information (including voice recordings).
I. Professional or employment-related information.
Current or past job history or performance evaluations.
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.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Sensitive Personal Information
Any information that reveals a, account credentials, precise geolocation, personal information concerning a consumer’s health as well as contents of mail, e-mail and text messages
Personal information does not include publicly available information from government records, information relating to our job applicants, employees, contractors or other personal, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA’s scope, such as information collected pursuant to the GLBA.
We have obtained the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from information we obtain in the course of providing our services to you, or from observing your actions on our website.
- From third-party business partners such as social media sites, ad networks, and analytics providers.
- Information that is publicly available online or elsewhere and
Company may use this information to:
- Provide you with the information, products, or services you request from us.
- Fulfill the reason you provided the information, such as to respond to customer service requests or other inquiries.
- Create, maintain, customize, and secure your account with us.
- Personalize your website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent where required by law).
- Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- Process your requests, purchases, transactions, and payments
- Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
- Prevent transactional fraud.
- 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.
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 notice to you. Such notice may be delivered, for example, by posting an updated California Privacy Notice.
Sharing Personal Information
Company may disclose your personal information to a third party for business purposes. When we do so, Company enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential; and (B) not use it for any purpose except performing the obligations under the contract.
We share your personal information with the following categories of third parties for a business purpose:
- Service providers.
- Data aggregators and analytic providers
- Internet cookie data recipients (e.g., Google analytics)
In the preceding twelve (12) months, Company has disclosed the following categories of personal information to the third parties listed above for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category D: Commercial Information
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category L: Sensitive Personal Information
If we have collected or received your data in connection with a financial product or service, you may have additional rights regarding this sharing which are described below.
Sale or Sharing of Personal Information.
The CCPA similarly requires Company to provide you with a statement on the sale of personal information. In the preceding twelve (12) months, Company has not sold personal information.
Notice Regarding Your Rights
Rights and Limitations on Use of Personal Information
You have the right to limit the use or disclosure of certain personal information, including “sensitive personal information.” Sensitive personal information is any information that reveals a consumer’s SSN, driver’s license number, or passport number, account credentials, precise geolocation, racial and ethnic origin, religious beliefs, biometric data, personal information concerning a consumer’s health or sex life or sexual orientation, as well as contents of a consumer’s mail, e-mail and text messages. As an employer, we intend to retain each category of personal information for two years after you cease employement or from the time you submitted your information for employement, whichever is longer, or for such time as required by law (if such time frame is longer).
In addition, with certain exceptions, you have the right to delete, know, correct, access, and request a copy of your personal information to move it elsewhere. In no event shall we discriminate based on such requests.
Access & Data Portability Rights
You have the right to request that Company disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:
- 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.
- The specific pieces of personal information we collected about you.
- If we sold or disclosed your personal information for a business purpose, two lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.
The CCPA provides a number of reasons why a deletion request may be denied. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
To request deletion of your Personal Information, you may submit a request through our Deletion Request Page or call us at 1-877-977-7709. If you choose to call us, please review the Deletion Request Page first because it contains important descriptions of the process we use to verify your identity and fulfill your request. You may also designate an authorized agent to submit a request on your behalf as described on the Deletion Request Page.
If we have collected financial information from you, then you have the right to restrict the sharing of personal financial information with our affiliates (companies we own or control, or that own or control us) and outside companies that we do business with. Such rights do not prohibit the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
You can choose to:
- Restrict Information Sharing With Companies We Own or Control, or That Own or Control Us (Affiliates): Unless you direct us not to, we may share personal and financial information about you with our affiliates (and those affiliates may use the information to market to you).
- Restrict the Sale of Personal Information to Third Parties
Please email us at firstname.lastname@example.org if you wish to exercise the option above.
Non-Financial Personal Information
If we collect information from you that is not related to a financial product or service, you have the right to request that Company does not sell or share that personal information as defined by the CCPA. To exercise that right, please click here: Do Not Sell or Share My Personal Information (https://www.totaldiabetessupply.com/pages/do-not-sell-or-share-my-personal-information) or writing to us at 3200 West Prospect Road, Suite 100, Fort Lauderdale, FL 33309.
Exercising Access, Data Portability, Opt-Out Rights, Correction and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Company by:
- Vising and submitting a request at our Access Request Page, Correction Request Page, and Deletion Request Page.
- Calling us at 1-877-977-7709
- Writing to us at 3200 West Prospect Road, Suite 100, Fort Lauderdale, FL 33309
- Via email at email@example.com (please include “California Privacy Request” in the subject line).
Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information.
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 Company to verify, to a reasonable degree of certainty, that you are the person about whom Company collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by Company, if any; and
- Describe your request with sufficient detail that allows Company 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 that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to 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
Company endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If Company requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time. For do not sell or share requests, we endeavor to respond to the verifiable request within fifteen (15) days.
If you have an online account with us, we will deliver our written response to your online 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 or have denied a request, if applicable.
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.
Company will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, Company 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.
Other California Privacy Rights
California’s "Shine the Light" law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at firstname.lastname@example.org or write to us at:
Total Diabetes Supply
3200 West Prospect Road, Ste. 100
Fort Lauderdale, FL 33309
Changes to Our Privacy Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
Please print and retain a copy of this California Privacy Notice for your records.