Effective Date: March, 2022
Last Updated: March, 2022
This Privacy Notice for California Residents supplements the information contained in the general privacy policy of Similasan Corporation (the “Company” or “we”) with respect to our Website (as defined in our general privacy policy) and applies solely to all visitors, users, and others who reside in the State of California ("California consumers" or "you"). We adopt this Privacy Notice for California Residents to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice for California Residents.
Information We Collect
We collect 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 as set forth in the CCPA ("personal information"). Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope.
In particular, we have collected the following categories of personal information from California consumers within the last twelve (12) months:
Category | Examples | Collected | Purposes (as described below under "Use of Personal Information") |
---|---|---|---|
A. Identifiers. | A real name, postal address, email address. | YES | A, E, I, K |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | Name, address, telephone number. | YES | A, E, I, K |
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). | YES (Only if submitted voluntarily and necessary for compliance with applicable laws.) | I |
D. Commercial information. | Products or services purchased. | YES | A, E I, K |
E. Biometric information. | Not applicable. | NO | Not applicable. |
F. Internet or other similar network activity. | Browing history, information on a consumer’s interaction with a website. | YES (Only through Google Analytics and Facebook Pixel.) | B, F, I, G, K |
G. Geolocation data. | Physical location or movements. | YES (Only through our Website’s store finder feature.) | F, I |
H. Sensory data. | Not applicable. | NO | Not applicable. |
I. Professional or employment-related information. | Not applicable. | NO | Not applicable. |
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)). | Not applicable. | NO | Not applicable. |
K. Inferences drawn from other Personal Information. | Not applicable. | NO | Not applicable. |
- Directly from you. For example, from forms you complete.
We obtain the categories of personal information F listed above from the following category of sources:
- Google Analytics and Facebook Pixel.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share Personal Information to request a price quote or ask a question about our products, we will use such Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use such Personal Information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including but not limited to processing your requests, purchases, transactions, and payments, and preventing transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your experience using the Website and to deliver content and product offerings relevant to your interests, including targeted offers and ads through the Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website and products.
- To respond to law enforcement requests and comply with by applicable law, court order, or governmental regulations, including but not limited to the U.S. Food and Drug Administration (“FDA”) rules and regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about the Website’s users is among the assets transferred.
- To notify you about changes to the Website or any products we offer or provide though it.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient both to keep that Personal Information confidential and not to use it for any purpose except performing the contract.
We may share your Personal Information with the following categories of third parties:
- Manufacturers, contractors, affiliates, service providers, advertisers, Pharmacovigilance provider.
- Any federal, state, local or foreign government or political subdivision thereof, or any agency or instrumentality of such government or political subdivision, or any self-regulated organization or other non-governmental regulatory authority or quasi-governmental authority (to the extent that the rules, regulations or orders of such organization or authority have the force of law), or any arbitrator, court or tribunal of competent jurisdiction, or any agent or service provider assisting us to comply with applicable laws, including but not limited to the rules and regulations of FDA, a court order and such other order of any governmental authority.
- Other third parties to support our business including but not limited to payment processing companies such as Google LLC and Meta Platforms, Inc.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below:
Personal Information Category | Category of Third-Party Recipients | |
---|---|---|
Business Purpose Disclosures | Sales | |
A: Identifiers. | Affiliate, Manufacturers, Costumer service providers, pharmacovigilance provider, FDA | None. |
B: California Customer Records Personal Information categories. | Affiliate, Manufacturers, Costumer service providers, pharmacovigilance provider, FDA | None. |
C: Protected classification characteristics under California or federal law. | None. | None. |
D: Commercial information. | Affiliate, Manufacturers, Costumer service providers, pharmacovigilance provider, FDA | None. |
E: Biometric information. | None. | None. |
F: Internet or other similar network activity. | Google LLC, Meta Platforms, Inc. | None. |
G: Geolocation data. | None. | None. |
H: Sensory data. | None. | None. |
I: Professional or employment-related information. | None. | None. |
J: Non-public education information. | None. | None. |
K: Inferences drawn from other personal information. | None. | None. |
Your Rights and Choices
The CCPA provides California consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- 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 (also called a data portability request).
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
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 applicable 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 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 including but not limited to our compliance related to the FDA rules and regulations.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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 either by:
Phone: +1 (800) 240-9780
Postal Address: 1805 Shea center drive suite 270, Highlands Ranch, CO 80129
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 twelve (12)-month period. The verifiable consumer request must:
- Provide information sufficient to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include but not limited to: name, address, and, if existing, account name and purchase history.
- Describe your request in detail sufficient to allow 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 that the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific 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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to a total of ninety (90) days), we will inform you in writing of the reason and extension period.
We will deliver our written response either electronically via email or via phone, at your discretion.
Any disclosures we provide will only cover the twelve (12)-month period preceding the 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 and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Sale of Personal Information
We do not currently sell any personal information.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.
- 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 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 contact us here or write to us at: 1805 Shea center drive suite 270, Highlands Ranch, CO 80129. Except for our affiliates and subsidiaries, our policy is not to disclose personal information collected online to a third party for their direct marketing purposes without your approval.
Changes to this Privacy Notice for California Residents
We reserve the right to amend this Privacy Notice for California Residents at our discretion and at any time. When we make changes to this Privacy Notice for California Residents, we will post the updated notice on the 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.
Contact Information
If you have any questions or comments about this Privacy Notice for California Residents, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1 (800) 240-9780
Postal Address: 1805 Shea center drive suite 270, Highlands Ranch, CO 80129