Dated: October 2021
Information We Collect
Categories of Personal Information. Marlow has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the Last Update of this CCPA Notice (“Last Update”). Personal Information does not include (i) publicly available information from government records; (ii) deidentified or aggregated Personal Information; or (iii) information excluded from the CCPA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act.
- Identifiers. A real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.
- Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)). A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, or any other financial information. Some Personal Information included in this category may overlap with other categories.
- Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data.
- Visual or similar information.
- Professional or employment-related information. Current or past job history
- Inferences. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Categories of Sources. We collect the Categories of Personal Information listed above from the following Categories of Sources: (i) directly from consumers (e.g., forms, surveys, responses, or other direct interactions from or with consumers), (ii) indirectly from consumers (e.g., consumer activity online, interactions with our Website and other sites), (iii) advertising networks that assist us with measuring, targeting, and placing advertisements (“Advertising Networks”), (iv) marketing platforms and partners which help us develop and deploy marketing strategies (“Marketing Partners”), (v) social networks used for retargeting and creating audiences (“Social Networks”), (vi) order management and logistics providers that help manage the shipment and delivery of our products (“Logistic Partners”), or (vii) e-commerce platform provider (“E-Commerce Provider”).
Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each, a “Business Purpose”): (i) to investigate and to manage enquiries, disputes and legal proceedings, (ii) to comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions, (iii) as described to you when collecting your Personal Information or as otherwise permissible under the CCPA, (iv) to evaluate or consummate 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 is among the assets transferred, (v) to process and fulfill orders and payments, (vi) to communicate with Website visitors, customers, subcontractors and vendors, including through email marketing, (vii) to develop, implement, market, promote, and sell our products and services, (viii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, (ix) to help troubleshoot technical errors, (x) to create, maintain, customize, and secure your account with us, (xi) to review and assess market trends and activities impacting our products and services, (xii) to personalize your Website experience and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email (with your consent, where required by law), (xiii) to operate the referral program and loyalty program, and (xiv) to review job applications evaluate job applicants.
Categories of Third-Party Recipients. We may share your Personal Information with the following Categories of Third-Party Recipients for Business Purposes:
- Service Providers, which include hosting providers, technical assistance and security, database management/back-up services, analytics, digital marketing (e.g., marketing automation), customer relationship management, customer service, providers of administrative services, payment processors, suppliers, distribution channels.
- Social Networks
- Advertising Networks
- Marketing Partners
- Government Entities
Your rights your choices
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them.
Right to Know About Personal Information. You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):
- Specific pieces of Personal Information we collected about you in the preceding twelve (12) months (also known as a data portability request)
- Categories of Personal Information we collected about you in the preceding twelve (12) months
- Categories of Sources from which the Personal Information was collected
- Our Business Purpose for collecting that Personal Information
- Categories of Personal Information we disclosed or sold for a Business Purpose and the Categories of Third-Party Recipients to whom the Personal Information was disclosed or sold
Right to Request Deletion. You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Exercising Rights to Know or Request Deletion. To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by either: (a) calling us at (929) 207-7069 or (b) submitting your request by email to email@example.com. You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) 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 Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you.
Verification Process. To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA. We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law. If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.
Response Timing and Format. We will confirm receipt of a verifiable consumer request within then (10) business days of its receipt. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. We will deliver our written response by mail or electronically. 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, 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 may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.
Right to Opt-Out of the Sale of Personal Information. If you are 16 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”). We do not knowingly sell the Personal Information of children under the age of 16, unless we receive affirmative authorization (the “right to opt-in”) from either (i) the consumer who is between 13 and 16 years of age, or (ii) the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to 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 visiting the following Internet Web page link:
Once you make an opt-out request, we will not ask you to reauthorize Personal Information sales for at least twelve (12) months. However, you may change your mind and opt back in to Personal Information sales at any time by following the instructions in the link below:
Do Not Sell My Personal Information
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You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CCPA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
Notice on Financial Incentives
We may offer you certain financial incentives permitted under the CCPA for the collection, sale or deletion of your Personal Information that may result in different prices, rates, or quality levels, provided that: (i) the financial incentive is reasonably related to the value of your Personal Information and (ii) we provide you written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Details about specific financial incentives such as materials terms, the Categories of Personal Information implicated, how you may opt-in to the incentive program, how you may exercise the right to withdraw, and a good faith estimate of the value of the data shall be disclosed to you at or before you opt-in to such financial incentives and provide Personal Information.
Right to Designate an Authorized Agent
If you submit a request to know, delete or opt-out of the sale of your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.
Other California Privacy Rights
Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
To make such a request, please send an email to firstname.lastname@example.org
Changes to Our CCPA Notice
This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without notice to you. By visiting or accessing the Website, purchasing products or services from us, or otherwise engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect. Please refer back to this CCPA Notice on a regular basis.
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: