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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020
Last Updated: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in HH Global Ltd.’s Privacy and Cookies Policy and applies solely to all visitors, users, consumers, and others who reside in the State of California (“consumers” or “you”). We adopt this notice 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 notice. 

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 or device (“personal information”). In particular, HH Global, including the website, www.hhglobal.com, has collected certain categories of personal information from consumers within the last twelve (12) months.  For purposes of illustration, the chart below provides examples of personal information within each category, some of which may not have been specifically collected by HH Global.

Category

Examples

Collected

Sources

Purpose

Third Parties Shared

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, company, or other similar identifiers.

YES

(a) Directly or indirectly from you
(b) From third parties, our clients

(a) Performance of a contract
(b) Necessary for our legitimate interests
(c) Necessary to comply with a legal obligation

(a) Print production vendors
(b) Promotional item vendors
(c) Fulfillment center vendors

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, physical characteristics or description, address, telephone number.

Some personal information included in this category may overlap with other categories.

YES

(a) Directly or indirectly from you
(b) From third parties, our clients

(a) Performance of a contract
(b) Necessary for our legitimate interests
(c) Necessary to comply with a legal obligation

(a) Print production vendors
(b) Promotional item vendors
(c) Fulfillment center vendors

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).

NO

N/A

N/A

N/A

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

N/A

N/A

N/A

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.

NO

N/A

N/A

N/A

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

(a) Indirectly from you
(b) From third parties, our clients

(a) Necessary for our legitimate interests
(b) Necessary to comply with a legal obligation

(a) Analytics and business intelligence vendors

G. Geolocation data.

Proximity of physical location based on IP address or movements. 

YES

(a) Indirectly from you
(b) From third parties, our clients

(a) Necessary for our legitimate interests
(b) Necessary to comply with a legal obligation

(a) Analytics and business intelligence vendors

H. Sensory data.

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

NO

N/A

N/A

N/A

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

N/A

N/A

N/A

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

N/A

N/A

N/A

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

N/A

N/A

N/A

Personal information does not include:

HH Global obtains the categories of personal information listed above from the following categories of sources:

For each category of personal information above, HH Global collects the information for the following business or commercial purposes(s): 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes: 

HH Global 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

HH Global may disclose your personal information to a third party for a business purpose. When we disclose 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 share your personal information with our service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, HH Global has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of service providers or third parties: print production vendors, promotional item vendors, and fulfillment center vendors.  

Sales of Personal Information 

In the preceding twelve (12) months, HH Global has not sold personal information.    

Your Rights and Choices 

The CCPA provides consumers (California residents) 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 HH Global disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

Deletion Request Rights 

You have the right to request that HH Global 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: 

Exercising Access, Data Portability, and Deletion Rights; Designating an Authorized Agent

To exercise the access, data portability, and deletion rights described above, or to designate an authorized agent, please submit a verifiable consumer request to us by either: 

Only you, an authorized agent, 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 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:

We will use the information you provide to verify your request against the records we maintain.  We will not use the information you provide to verify your request for any other purpose. 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 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

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

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, 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. 

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell the personal information of consumers.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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 send an email to Data.Protection@hhglobal.com or write us at: Vice President of Legal, Americas, 520 Lake Cook Road, Suite 680, Deerfield, Illinois, 60015. 

Changes to Our Privacy Notice

HH Global reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, 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 notice, the ways in which HH Global collects and uses your information described herein and in the Privacy and Cookies Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our Vice President of Legal, Americas at:

Toll Free Phone: 866-475-5652
Website: www.hhglobal.com
Email: Data.Protection@hhglobal.com 
Postal Address: 

HH Associates US, Inc.
Attn: Vice President of Legal, Americas
520 Lake Cook Road
Suite 680
Deerfield, Illinois, 60015

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