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Privacy Notice for California Residents

Last Reviewed on: 8/5/2020

This Privacy Notice for California Residents (“CCPA Notice”) supplements the information contained in Fleet Feet’s Privacy Policy. This CCPA Notice applies solely to all visitors, users, and others who reside in the State of California, and to 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 California consumer, household or device (“California Personal Information”). Fleet Feet provides this CCPA Notice to comply with our obligations in our capacity as a “Business” under the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used in this CCPA Notice, but not defined will have the meaning ascribed to it in the CCPA or our Privacy Policy, as applicable.

If you are a California resident looking to exercise your rights under the CCPA, please see the section below on Exercising Access, Opt-Out, and Deletion Rights.

As used in this CCPA Notice, the term “California Personal Information” does not include:

  • publicly available information lawfully made available from federal, state, or local government records;
  • deidentified or aggregated consumer information; or
  • other information excluded from the CCPA’s scope, including:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Driver’s Privacy Protection Act of 1994, the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act.

California Personal Information We Collect

In the twelve (12) months prior to the “Last Reviewed” date of this CCPA Notice, we have collected the following categories of California Personal Information:

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).

YES

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, keystroke, gait and foot scans including video data of walking and/or running motion, or other physical patterns, and sleep, health, or exercise data.

YES

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.

YES

H. Sensory data.

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

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

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.

YES

Sources of California Personal Information

We collect the categories of California Personal Information listed above from the following categories of sources:

  • Directly from you, including when you provide information to us.
  • Indirectly from you, such as when we automatically collect technical and usage information when you visit our Sites or use our Services.
  • Affiliated companies.
  • Franchisees and their affiliated companies, service providers and vendors.
  • Public and publicly available sources.
  • Third party websites.

Purposes for Which We Collect and Use California Personal Information

We may use or disclose the California Personal Information listed above for the following business and commercial purposes:

  • All uses described under the “How We Use Your Information” section of our Privacy Policy.
  • To conduct recruiting and candidate evaluation activities and to inform our employment decisions.
  • To provide, support, personalize, and develop our Sites and Services.
  • To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including advertisements.
  • To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
  • To maintain the safety, security, and integrity of our Sites, Apps, other technology assets, and our Services, including the detection of security incidents.
  • To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Services.
  • To develop, improve, and deliver marketing and advertising.
  • Product recommendations based on preferences and biomechanical information, including foot scans with videos of walking and/or running motion data
  • For internal operational uses such as research, analytics, development, audits, and security.
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy.
  • 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.
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
  • For any other purpose described to you when collecting your California Personal Information before or at the time of collection.

We will not collect additional categories of California Personal Information or use the California Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of California Personal Information

We may disclose your California Personal Information to a third party for a business purpose. When we disclose California Personal Information for a business purpose, we enter a contract 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.

We may share and disclose your California Personal Information with the following categories of third parties:

  • Our affiliated companies.
  • Our customers.
  • Our vendors.
  • Our service providers.
  • Franchisees and their affiliated companies, service providers and vendors.
  • Other third parties to protect our legal rights or comply with legal requirements.
  • Other third parties as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
  • Other third parties involved in a merger, sale, joint venture or other transaction involving a transfer of our business or assets.
  • Other third parties with your prior consent.

In the twelve (12) months prior to the “Last Reviewed” date identified at the beginning of this CCPA Notice, Fleet Feet has disclosed the following categories of California Personal Information for a business purpose:

Category A: Identifiers.

Category B: Personal information.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category E: Biometric information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category K: Inferences drawn from other personal information.

We disclosed your California Personal Information for a business purpose to the following categories of third parties:

  • Affiliated companies
  • Vendors.
  • Service providers.
  • Franchisees and their affiliated companies, service providers and vendors.

Sales of California Personal Information

In the past twelve (12) months prior to the “Last Reviewed” date of this Notice, Fleet Feet has sold the following categories of California Personal Information:

Category A. Identifiers.

Category B. Personal information.

Category D. Commercial information.

Category F. Internet or other similar network activity.

Your Rights and Choices with Respect to California Personal Information

The CCPA provides California residents with specific rights regarding California Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your California Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the section below on Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of California Personal Information we collected about you.
  • The categories of sources for the California Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that California Personal Information.
  • The categories of third parties with whom we share that California Personal Information.
  • The specific pieces of California Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your California Personal Information for a business purpose, we will provide you with details of the:
    • sales, identifying the California Personal Information categories sold and purchased; and
    • purposes for the disclosures, identifying the California Personal Information categories disclosed.

Deletion Request Rights

You have the right to request that we delete any of your California Personal Information, 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 California Personal Information from our records, unless an exception under CCPA applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the California 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.

Exercising Access, Opt-Out, and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your California 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. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized representative, and
  • 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 your California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use California Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see California Personal Information Sales Opt-Out and Opt-In Rights.

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, we will inform you of the reason and extension period in writing.

We will deliver an electronic written response to the email address associated with the verifiable consumer request. We can also respond by mail, at your option.

Any disclosures we provide in response to a request will only cover the 12-month period preceding the receipt of the 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 California 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 we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

California Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your California Personal Information at any time (the "right to opt-out"). We do not sell California Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to California Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by either:

We endeavor to comply with a verifiable consumer request to opt-out within fifteen (15) days of its receipt. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize California Personal Information sales. However, you may change your mind and opt back in to California Personal Information sales at any time by either:

You do not need to create an account with us to exercise your opt-out rights. We will only use California Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

You have a right to not receive discriminatory treatment for exercising your CCPA rights, and we will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California Civil Code Section 1798.83 permits users of our Sites and App 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: privacy@fleetfeet.com or write us at: Fleet Feet, Inc., Re: Data Privacy, 310 East Main Street, Suite 200, Carrboro, NC 27510.

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org

Changes to this CCPA Notice

We reserve the right to amend this CCPA Notice at our discretion and at any time. When we make changes to this CCPA Notice, we will post the updated notice to our Sites and update the notice’s date. Your continued use of our Sites and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy and this CCPA Notice periodically for updates.