(A) Introduction
The controllers listed in this policy (collectively referred to as "AOLSTECELL," "we," or "our"), and applies to external individuals who interact with us, including customers, website visitors, recipients of other products and services, employees of business clients and suppliers, job applicants, and visitors to our premises (collectively referred to as "you").
This policy may be revised or updated from time to time to reflect changes in our practices regarding the handling of personal data and personal information, or changes in applicable laws. We recommend that you read this policy carefully and review this page regularly to stay informed about any changes we may make pursuant to the terms of this policy.
You may have certain rights related to the information we collect about you. Specifically, the rights of data subjects under the General Data Protection Regulation (GDPR) are explained in Section (L) below. Likewise, U.S. residents (particularly California residents) can find information about their consumer rights in Section (T) below.
This policy was last updated on November 19, 2025.
(B) Collection of Personal Data
Collection of Personal Data: We collect or obtain your personal data through the following means:
- Data provided to us: We obtain personal data when it is provided to us (for example, when you register an account with us; when you contact us by email, phone, or any other method; when you provide us with your business card; or when you submit a job application).
- Relationship data: We collect or obtain personal data in the normal course of our relationship with you (for example, when we provide services to you).
- Data you make public: We collect or obtain personal data that you have chosen to make public, including personal data that you make public through social media (for example, if you publicly post content about us, we may collect information from your social media profile).
- Website data: We collect or obtain personal data when you visit any of our websites or use any features or resources provided on or through the websites.
- Registration details: We collect or obtain personal data when you use or register to use any of our websites, products, or services.
- Content and advertising information: If you interact with any third-party content or advertising on our websites (including third-party plugins and cookies), we will receive personal data from the relevant third-party providers of that content or advertising.
- Third-party information: We collect or obtain personal data from third parties who provide personal data to us (e.g., credit reference agencies; law enforcement agencies, etc.).
(C) Creation of Personal Data
In certain circumstances, we also create personal data about you, such as records of your interactions with us and details of your past interactions with us. We may also combine personal data from any of our websites, products, or services, including data collected from different devices.
(D) Categories of Personal Data We Process
We process the following categories of personal data about you:
- Personal information: name; preferred name; and photographs.
- Demographic information: gender; date of birth/age; nationality/region; and language preferences.
- Contact details: address; delivery address; phone number; email address; online communication information; and social media information.
- Consent records: records of any consent you have given, including the date and time, method of consent, and any related information (e.g., the subject of the consent).
- Purchase details: purchase records and prices; recipient name; address; phone number; email address; return details; warranty details.
- Payment details: invoice records; payment records; billing address; payment method; last four digits of bank account or credit card number; cardholder or account holder name; card or account security details; card "valid from" date; card expiry date.
- Website-related data: Internet Protocol (IP) address; internet service provider; referring/exit pages; language settings; date and time of connection to the website.
- Server logs: records of events on our servers, including search queries; IP addresses; hardware settings; browser type; browser language; date and time of requests; referring URLs; and certain cookies that identify your browser or account.
- Content and advertising data: records of your interactions with our online advertisements and content; records of advertisements and content displayed on pages you view; and any interactions you may have with such content or advertisements (e.g., mouse hover, clicks, or any forms you fill in partly or fully).
- Views and opinions: any comments, views, and opinions you choose to send to us or publicly post about us on social media platforms.
- Cookie data: personal data collected through cookies and other similar technologies.
(E) Purposes of Processing and Legal Bases for Processing
In accordance with applicable laws, the purposes for which we process personal data and the legal bases on which we carry out such processing are as follows:
| Processing Activities |
Legal Basis for Processing |
| Website provision: providing our websites; providing promotional items upon request; and communicating with you regarding these websites. |
· The processing of your personal data is necessary for the performance of any contract entered into between you and us, or necessary to take steps at your request prior to entering into a contract with us;
· We have a legitimate interest in carrying out the processing for the purpose of providing our website services (provided that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
· We have obtained your prior consent to the processing (this legal basis is used only for entirely voluntary processing and not for any necessary or mandatory processing).
|
| Operating our business: operating and managing our websites; providing content to you; presenting advertisements and other information to you; analyzing trends, usage, and activities; communicating and interacting with you through our websites; developing and displaying content, features, and advertising tailored to your interests on our services and on other platforms; and notifying you of any changes to our websites. |
· Processing your personal data is necessary for the performance of any contract we have entered into with you, or to take steps at your request prior to entering into a contract with us; or
· We have a legitimate interest in carrying out the processing in order to provide our websites or services to you (provided that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
· We have obtained your prior consent to the processing (this legal basis applies only to entirely voluntary processing — not to any processing that is necessary or mandatory).
|
| Communications and marketing: Communicating with you by any means (including email, telephone, SMS, social media, post, or in person) to provide you with news and other information that may interest you — always obtaining your prior opt-in consent where required by applicable law; personalizing our websites for you; maintaining and updating your contact details where appropriate; obtaining your prior opt-in consent where required; and enabling and recording your opt-out or unsubscribe preferences where applicable. |
· Processing your personal data is necessary for the performance of any contract we have entered into with you, or in order to take steps at your request prior to entering into such a contract; or
· We have a legitimate interest in processing your personal data in order to communicate with you, always in compliance with applicable laws (provided that such legitimate interest is not overridden by your interests or fundamental rights and freedoms); or
· We have obtained your prior consent to the processing (this legal basis applies only to entirely voluntary processing — not to any processing that is necessary or mandatory).
|
| Product safety communications: Communications related to product safety, including product recalls and product safety advisory notifications. |
· The processing is necessary for compliance with a legal obligation; or
· We have a legitimate interest in processing to ensure the safety and proper use of our products (provided that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
|
| IT system administration: Managing and operating our communications, IT, and security systems; and auditing (including security audits) and monitoring these systems. |
· The processing is necessary for compliance with a legal obligation; or
· We have a legitimate interest in carrying out the processing in order to manage and maintain our communications and IT systems (provided that such legitimate interest is not overridden by your interests or fundamental rights and freedoms).
|
| Financial management: Sales; finance; corporate auditing; and supplier management. |
· We have a legitimate interest in carrying out the processing in order to manage and operate the financial affairs of our business (provided that such legitimate interest is not overridden by your interests or fundamental rights and freedoms); or
· We have obtained your prior consent to the processing (this legal basis is used only for entirely voluntary processing and not for any processing that is necessary or mandatory).
|
| Surveys: Engaging with you to obtain your views about our website. |
· We have a legitimate interest in processing the data in order to carry out surveys, satisfaction reporting, and market research (provided that your interests or fundamental rights and freedoms do not override this legitimate interest); or
· We have obtained your prior consent to the processing (this legal basis is used only for entirely voluntary processing and not for any processing that is necessary or mandatory).
|
| Security: The physical security of our premises (including records of access to our premises). |
· The processing is necessary for compliance with a legal obligation; or
· We have a legitimate interest in carrying out the processing to ensure the physical and electronic security of our business and premises (provided that such legitimate interest is not overridden by your interests or fundamental rights and freedoms).
|
| Investigation: Detecting, investigating, and preventing policy violations and criminal activities in accordance with applicable laws. |
·The processing is necessary for compliance with legal obligations; or
·We have a legitimate interest in processing for the purpose of detecting and preventing violations of our policies and applicable laws (provided that such legitimate interest does not override your interests, fundamental rights, or freedoms).
|
| Legal compliance: Complying with legal and regulatory obligations under applicable laws. |
The processing is necessary for the performance of legal obligations. |
| Improving our website: Identifying issues on our website; planning improvements; and creating new websites. |
·We have a legitimate interest in processing data to improve our website (provided that your interests, fundamental rights, or freedoms do not override this legitimate interest); or
·We have obtained your prior consent for the processing (this legal basis applies only to fully voluntary processing and not to any necessary or mandatory processing).
|
| Fraud prevention: Detecting, preventing, and investigating fraud, violations of policies or terms, and threats or harms. |
·The processing of data is necessary for compliance with legal obligations (in particular, obligations under applicable labor laws); or
·We have a legitimate interest in processing for the purpose of detecting and preventing fraud (provided that such legitimate interest does not override your interests, fundamental rights, or freedoms).
|
| ·Establishment, exercise, and defense of legal claims: Managing legal claims; establishing facts and claims, including the collection, review, and presentation of documents, facts, evidence, and witness statements; and exercising and defending legal rights and claims, including formal legal proceedings. |
·The processing is necessary for compliance with legal obligations;
·We have a legitimate interest in processing to establish, exercise, or defend our legal rights (provided that such legitimate interest does not override your interests, fundamental rights, or freedoms); or
·The processing is necessary for the establishment, exercise, or defense of legal rights.
|
(F) Disclosure of Personal Data to Third Parties
We may disclose personal data to other entities within the AOLSTECELL team for legitimate business purposes, to operate our website for you, and to comply with applicable laws. In addition, we may disclose personal data to:
- You and, where appropriate, your designated representatives;
- As required by law or regulatory authorities, or to report any actual or suspected violations of applicable laws or regulations;
- Accountants, auditors, consultants, lawyers, and other external professional advisors, bound by enforceable confidentiality obligations;
- Third-party processors (such as email service providers; marketing/advertising service providers; site operators; payment service providers; shipping companies; postal carriers, etc.) located anywhere in the world, provided they comply with the requirements set out in Section (G);
- Any relevant parties, regulators, government agencies, law enforcement authorities, or courts, to the extent necessary to establish, exercise, or defend legal rights;
- Any relevant parties, regulators, government agencies, law enforcement authorities, or courts, for the purpose of preventing, investigating, detecting, or prosecuting criminal offenses or enforcing criminal penalties;
- Any relevant third-party acquirers or successors if we sell or transfer all or any part of our business or assets (including in the case of a reorganization, dissolution, or liquidation); and
- Any relevant third-party providers, as our website and applications may use third-party advertising, plugins, or content. If you choose to interact with any such advertising, plugins, or content, your personal data may be shared with the relevant third-party providers. We recommend that you review their privacy policies before interacting with third-party advertising, plugins, or content.
If we engage third-party processors to process your personal data, such processors will be subject to binding contractual obligations to: (i) process personal data only in accordance with our prior written instructions; and (ii) take measures to protect the confidentiality and security of personal data; and any other requirements imposed by applicable law.
(G) International Transfer of Personal Data
Given the international nature of our business, we may transfer personal data within the AOLSTECELL team and to the third parties described in Section (F) for the purposes set out in this Policy. Therefore, personal data may be transferred to other countries/regions, the laws and data protection compliance requirements of which may differ from those of your country/region, including China, the European Union, the United Kingdom, and the United States.
Where exemptions or exceptions apply (for example, transfers necessary to establish, exercise, or defend legal claims), we may transfer data at our discretion based on such exemptions or exceptions. If no exemption or exception applies and we transfer your personal data from the United Kingdom or the European Economic Area to recipients outside the United Kingdom or the European Economic Area (as applicable) that are not in adequacy jurisdictions, such transfers will be conducted in accordance with the [Standard Contractual Clauses]. You have the right to request a copy of our [Standard Contractual Clauses] using the contact details provided in Section (U) below.
Please note that when you directly transfer any personal data to any AOLSTECELL entity located outside the United Kingdom or the European Economic Area (as applicable), we do not assume any responsibility for such transfers. Nevertheless, we will continue to process such data in accordance with this Policy from the date we receive it.
(H) Data Security
We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing in accordance with applicable laws.
As the Internet is an open system, information transmitted over the Internet is not completely secure. Although we take all reasonable measures to protect your personal data, we cannot guarantee the security of any data you transmit to us over the Internet—any such transmission is at your own risk, and you are responsible for ensuring that any personal data you send to us is transmitted securely.
(I) Data Accuracy
We take all reasonable measures to ensure that:
- The personal data we process about you is accurate and, where necessary, kept up to date;
- Any inaccurate personal data we process (considering the purposes of the processing) is promptly deleted or corrected.
We may periodically ask you to verify the accuracy of your personal data.
(J) Data Minimization
We take all reasonable measures to ensure that the personal data we process about you is limited to what is reasonably necessary for the purposes described in this Policy.
(K) Data Retention
We take all reasonable measures to ensure that your personal data is processed only for the shortest time necessary to achieve the purposes described in this Policy. The criteria we use to determine the retention period for your personal data are as follows:
(1) We will retain personal data in a form that allows identification only for the following periods:
While we maintain an ongoing relationship with you (e.g., you are a user of our services, or you are lawfully on our mailing list and have not unsubscribed); or
For the legitimate purposes set out in this Policy, we need to process your personal data and have a valid legal basis (e.g., your personal data is included in a contract between you and your employer, and we have a legitimate interest in processing this personal data to conduct our business and fulfill our obligations under that contract; or we have a legal obligation to retain your personal data).
(2) Duration:
Any applicable statute of limitations under law (i.e., any period during which someone may bring a legal claim against us regarding your personal data or any matter related to your personal data); and
An additional two (2) months after the end of the applicable statute of limitations period (so that if a claim is made at the end of the statute of limitations period, we still have a reasonable time to identify any personal data related to that claim).
(3) In addition, if any related legal claims are brought, we will continue processing personal data until the necessary period related to such claims has expired.
During the periods described in paragraphs (2)(a) and (2)(b) above, we will limit the processing of your personal data to storing and maintaining its security, except where reviewing such data is necessary for any legal claims or obligations under applicable law.
After the periods described in paragraphs (1), (2), and (3) above have expired, we will take one of the following measures:
Permanently delete or destroy the relevant personal data; or
Anonymize the relevant personal data.
(L) Your Legal Rights
Under applicable law, you may have the following rights regarding the processing of your relevant personal data:
- You have the right not to provide your personal data to us (however, please note that if you do not provide your personal data, we may be unable to provide you with the full functionality of our website—for example, we may not be able to process your requests without the necessary details);
- You have the right to access or obtain a copy of your relevant personal data, as well as information about the nature, processing, and disclosure of such data;
- You have the right to request correction of any inaccuracies in your relevant personal data;
- For legitimate reasons, you have the right to request the deletion of your relevant personal data or to restrict the processing of your relevant personal data;
- You have the right, where applicable, to transfer certain relevant personal data in a structured, commonly used, and machine-readable format to another controller;
- If we process your relevant personal data based on your consent, you have the right to withdraw that consent (please note that such withdrawal does not affect the lawfulness of any processing carried out prior to the date we receive the withdrawal, nor does it prevent us from processing your personal data based on any other available legal basis); and
- You have the right to lodge a complaint with a data protection authority regarding the processing of your relevant personal data (in particular, the UK Information Commissioner's Office, or the data protection authority of your country of residence, place of work, or where the alleged infringement occurred, if applicable).
Under applicable law, you may also have the following additional rights regarding the processing of your relevant personal data:
You have the right to object, on grounds relating to your particular situation, to our or our representatives’ processing of your relevant personal data if such processing is based on Article 6(1)(e) (public interest) or Article 6(1)(f) (legitimate interests) of the General Data Protection Regulation (GDPR); and
You have the right to object to our or our representatives’ processing of your relevant personal data for direct marketing purposes.
These rights do not affect your statutory rights.
To exercise any of the rights listed above, or if you have any questions regarding these rights, this Policy, or our processing of your personal data, please use the contact details provided in Section (Q) below. Please note:
In certain cases, we may require you to provide proof of identity in order to exercise these rights;
If your request requires the determination of additional facts (e.g., determining whether any processing does not comply with applicable law), we will investigate your request within a reasonable time before deciding on any action.
(M) Terms of Service
Use of our website or services is subject to our Terms of Service. We recommend that you review our Terms of Service regularly to stay informed of any changes we may make from time to time.
(N) Direct Marketing
We process your personal data in order to contact you via email, telephone, direct mail, or other communication methods to provide you with information about our website that may be of interest to you. We also process your personal data to present content tailored to your use of our website, applications, products, or services. If we provide website services to you, we may send or display information about our website, upcoming promotions, and other content that may interest you, using the contact information you provide or any other appropriate means, always subject to obtaining your prior consent as required by applicable law.
You can unsubscribe from our promotional mailing list at any time by clicking the unsubscribe link included in each promotional email we send. After unsubscribing, we will no longer send you promotional emails, but in certain cases, we may still contact you as necessary for the website, application, product, or service you have requested.
(Q) Analytics and Personalized Advertising
When you visit this website, we generally place cookies. We install cookies on your device or read cookies already on your device, always obtaining your consent where necessary under applicable law. We use cookies to record information about your device, browser, and, in some cases, your preferences and browsing habits. In accordance with applicable law, we process personal data through cookies and similar technologies.
When you use our website, certain third parties may store cookies on your device. We cannot control these cookies or how these third parties use them. These cookies allow third parties to provide services for us, such as analyzing the effectiveness of our marketing activities and user behavior.
Generally, most commercial browsers include tools to disable or delete standard cookies; in some cases, you can also block their future use through specific settings. Because browser functions and options vary, you may need to configure each one individually. For our web services, you can stop the collection of all information through a service by ceasing to use that service. Additionally, you can adjust privacy settings on your mobile device or browser to enable or disable certain location-based services. You can also choose to opt out of Google Analytics cookies by visiting https://tools.google.com/dlpage/gaoptout or by downloading the Google Analytics opt-out browser plugin.
(R) Do Not Track
Most browsers can be configured to send a signal to third-party websites requesting that they do not track users’ activities. Currently, we do not respond to "Do Not Track" signals. Therefore, even if we receive a "Do Not Track" signal, third parties may still track and collect information about your online activities while you visit, leave, or use our online services.
(S) California Consumer Privacy Act (CCPA) Disclosures
Under the California Consumer Privacy Act ("CCPA"), we are required to disclose our practices regarding the collection, use, and disclosure of personal information of California residents ("consumers"). Consumers also have additional rights regarding their personal information collected by us, including the right to access, delete, and not be discriminated against. This section of the Privacy Policy contains the disclosures required by the CCPA, and Section (V) below describes the rights that consumers have. We also describe how consumers can exercise these rights and some statutory exceptions that may apply. This Section (S) applies to the AOLSTECELL website.
Collection of Personal Information
We have collected and will continue to collect the following categories of consumers’ personal information:
- Personal identification information, including name, postal (billing) address, and email address;
- Categories of personal information specifically enumerated by law, such as under California Civil Code Section 1798.80(e), including telephone numbers and the last four digits of payment card numbers;
- Protected classifications, including date of birth and nationality;
- Commercial information, including records of products or services purchased; and
- Internet or other electronic network activity information, including browsing history and search history on the AOLSTECELL website.
Use of Personal Information
We may use the categories of personal information described above for the following commercial or business purposes:
- To comply with applicable legal and law enforcement requirements;
- To promote commercial or economic interests (e.g., to encourage others to purchase, join, subscribe, or provide products, goods, property, information, or services, or directly or indirectly facilitate or complete commercial transactions);
- To prevent malicious, deceptive, fraudulent, or illegal activities;
- To maintain or service customer accounts;
- To provide customer support and services; process or complete orders and transactions;
- To verify customer information;
- To process payments;
- To provide advertising or marketing services.
(T) Categories of Sources of Personal Information
We collect or obtain your personal information on our website and applications through the following means:
- Data provided by consumers and application users: We obtain this information when users provide personal information to us (for example, when you create an account, contact us via email, telephone, or any other method, or submit a job application).
Disclosure of Personal Information
We do not sell any personal information to third parties, and we specifically do not sell personal information of minors under 16 years of age. In the past 12 months, we have disclosed the following categories of personal information to the following categories of recipients:
| Recipient Category |
Category of Personal Information |
| Advertising networks, data analytics providers |
Personal identification information |
| Internet service providers |
Personal identification information;
Categories of personal information listed under California Civil Code Section 1798.80(e)
|
| Vendors that may need access to your personal information to help us provide services |
Personal identification information;
Categories of personal information listed under California Civil Code Section 1798.80(e);
Internet or other electronic network activity information;
Commercial information
|
| Payment processors |
Personal identification information;
Categories of personal information listed under California Civil Code Section 1798.80(e);
Internet or other electronic network activity information;
Commercial information
|
Disclosure of Personal Information and California Consumer Privacy Rights
The purposes for which we disclose personal information are described in more detail in Section (G) above.
California Consumer Privacy Act (CCPA) Rights
If you are a consumer, under the California Consumer Privacy Act (CCPA), you have the following rights regarding your personal information. Generally, to verify your request to exercise these rights, we will compare the personal information we have about you with the information you provide when submitting your request. Verification information may include your name, email address, phone number, or mailing address. We will respond to your verifiable consumer request within 45 days of receipt. To exercise your rights under the CCPA, please follow the instructions in this section.
Right to Know
Consumers have the right to submit a verifiable consumer request to obtain the following information for the 12 months preceding the request:
- The categories of personal information we have collected about you;
- The purposes for which we use each category of personal information collected about you;
- The categories of sources from which we collect personal information about you;
- The categories of third parties with whom we share personal information;
- The business or commercial purposes for collecting personal information;
- The specific pieces of personal information we have collected about you; and
- The categories of personal information disclosed for a business purpose.
Consumers may submit verifiable requests for this information via email: [email protected]
Right to Delete
Consumers have the right to request the deletion of any personal information we have collected. However, we are not required to comply with a deletion request if we need to retain the personal information for the following purposes:
- To complete the transaction for which the personal information was collected, provide the requested goods or services, take actions reasonably expected within the context of an ongoing business relationship, or otherwise fulfill a contract between you and us;
- To detect security incidents, prevent malicious, deceptive, fraudulent, or illegal activities, or prosecute those responsible for such activities;
- To debug products to identify and repair errors affecting existing functionality;
- To exercise free speech, ensure the rights of other consumers to exercise their free speech, or exercise other legally protected rights;
- To comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.);
- To engage in public interest, scientific, historical, or statistical research in compliance with all other applicable ethical and privacy laws, where deletion may render the research impossible or seriously impair the results, provided you have given prior informed consent;
- For internal uses aligned with the reasonable expectations of consumers based on your relationship with us;
- To comply with a legal obligation; or
- To use the information for other internal lawful purposes, provided it does not exceed the context in which it was provided.
Consumers may submit verifiable deletion requests via email: [email protected]
Non-Discrimination Rights
Consumers exercising their rights under the CCPA are entitled to be free from discrimination. We may not:
- Refuse to provide goods or services;
- Charge different prices or rates, including through discounts or other benefits or penalties;
- Provide a different level or quality of goods or services; or
- Suggest that you may receive a different price, level, or quality of goods or services.
Financial Incentives
We do not offer any financial incentives, pricing, or service-related benefits to consumers in exchange for personal information.
Authorized Agents
Under the CCPA, you may designate an authorized agent to submit requests to exercise your rights on your behalf. If you choose to do so, to protect your and our interests, we will require your authorized agent to provide a signed authorization confirming they are authorized to submit the request on your behalf. If the agent fails to provide proof of authorization, we will deny the request.
California "Shine the Light" Law
Under the California "Shine the Light" law, California residents have the right to request a notice describing the categories of customer personal information shared with third parties or affiliated companies for their direct marketing purposes. The notice will include the categories of information shared and a list of the third parties and affiliated companies with their names and addresses. If you are a California resident and wish to receive a copy of this notice, please send a written request to [email protected].
(U) Contact Us
If you have any questions or concerns regarding our Privacy Policy, please contact us at [email protected].
(V) Definitions
- "Adequate jurisdiction" refers to a jurisdiction formally designated by the European Commission that provides adequate protection for personal data.
- "California resident" means (1) any individual present in California other than for temporary or transitory purposes, and (2) any individual domiciled in California but temporarily outside the state.
- "Cookie" refers to a small file placed on your device when you visit a website, including our website. In this policy, "Cookie" also includes similar technologies such as web beacons and transparent GIFs.
- "Controller" refers to an entity that determines how and why personal data is processed. In many jurisdictions, the controller bears primary responsibility for compliance with applicable data protection laws.
- "Data protection authority" refers to an independent public authority responsible for overseeing compliance with applicable data protection laws.
- "EEA" means the European Economic Area.
- "GDPR" means the General Data Protection Regulation (EU) 2016/679.
- "Personal data" refers to information relating to any individual, or information from which an individual can be directly or indirectly identified, especially through identifiers such as name, identification number, location data, online identifiers, or through one or more factors related to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.
- "Personal information" refers to information that identifies, relates to, describes, or can reasonably be associated with a particular consumer or household. Personal information includes, but is not limited to, the following, provided it can reasonably be linked to a consumer or household:
- Personal identifiers;
- Categories of personal information listed under California Civil Code Section 1798.80(e);
- Protected classifications under California or federal law;
- Commercial information;
- Biometric information;
- Internet or other electronic network activity information;
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information; and
- Inferences used to create consumer profiles.
- "Processing," "processed," or "process" refers to any operation performed on personal data, whether or not automated, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- "Processor" refers to any individual or entity that processes personal data on behalf of a controller (excluding employees of the controller).
- "Profiling" means any form of automated processing of personal data, including using personal data to evaluate certain personal aspects related to a natural person, particularly to analyze or predict aspects concerning that person's work performance, economic situation, health, preferences, interests, reliability, behavior, location, or movements.
- "Relevant personal data" refers to personal data for which we act as the controller.
- "Sale" refers to the exchange of consumer personal information by a business for monetary or other valuable consideration to another business or third party, whether by sale, rental, release, disclosure, dissemination, transfer, or other means, including orally, in writing, electronically, or otherwise. Exceptions to a sale include:
- The consumer intentionally provides personal information or intentionally interacts with a third party, provided that third party does not sell the information, unless otherwise permitted;
- The business uses or shares personal information of consumers who have opted out of sales to inform third parties of the consumer’s choice;
- The business may use or share necessary personal information with service providers for business purposes, provided the business has given notice in its terms and conditions, and the service provider does not further collect, sell, or use the information beyond the business purpose; or
- The business transfers personal information as part of a merger, acquisition, bankruptcy, or other transaction in which a third party controls the business in whole or in part, provided the use or sharing complies with CCPA Sections 1798.110 and 1798.115.
- "Sensitive personal data" refers to personal data concerning race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual orientation, any actual or alleged criminal offenses or penalties, national identification number, or any other information deemed sensitive under applicable law.
- "Standard contractual clauses" refers to template transfer clauses adopted by the European Commission or a data protection authority and approved by the European Commission.
- "Website" refers to any website operated or maintained by us or on our behalf.