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This Supplemental California Privacy Disclosures (this “Supplement”) describes how Millwood, Inc. and its subsidiaries, affiliates, and related entities (collectively, “Company,” “we,” “our,” or “us”) collect and process Personal Information (as defined below) about our consumers who reside in the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). This Supplement supplements the information contained in our Privacy Policy and applies solely to individuals that reside in the State of California (“consumers” or “you”).
For a detailed description of how we collect, use, disclose, and otherwise process personal information, please see our Privacy Policy.
Unless otherwise expressly stated, all terms in this Supplement have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.
“Personal Information” in this Supplement means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information, lawfully obtained, truthful information that is a matter of public concern, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you, or information that is otherwise excluded from the CCPA’s scope.
We collect the categories of Personal Information listed above from the following categories of sources:
We only use sensitive personal information for the purposes set forth in our Privacy Policy to the extent necessary to process your job application at your request, to process financial transactions you initiate, to enter into and perform a contract with you, to comply with legal and regulatory requirements, and to protect the life or physical safety of anyone or as otherwise permissible for our own internal purposes consistent with applicable laws.
We may at times receive, or process Personal Information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
We collect Personal Information from and about you for a variety of purposes. For example, we use Personal Information to carry out obligations arising from agreements with you, process payments and transactions, identify and communicate with you, provide requested information and services, conduct research and analysis, improve our Website and services, enhance your experience, and communicate about our products, services, and activities. For more information about our use of personal information, please refer to our Privacy Policy: “How We Use Personal Identifying Information We Collect.”
We may disclose the Personal Information we collect to third parties for the business purposes described in our Privacy Policy, such as to engage third parties for payment processing and to support our business functions. We will only use, share, or disclose your Personal Information where: (1) you have provided your consent; (2) the disclosure is necessary for the performance of a contract; (3) we are required by law; (4) the disclosure is required to protect vital interests; or (5) the disclosure is necessary for the purposes of our legitimate commercial interests, provided your interests and fundamental rights do not override those interests.
We may share aggregated, non-personally-identifiable site use data with third parties.
Millwood, Inc. states in its Privacy Policy that it may keep information provided indefinitely. We retain Personal Information only for as long as is reasonably necessary to fulfil the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until such retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, or accounting requirements set by a legislature, regulator, or other government authority.
If you are a California resident, the CCPA grants you the following rights regarding your personal information:
You have the right to confirm whether we are processing Personal Information about you and to obtain certain personalized details about the Personal Information we have collected about you, including the:
You have the right to obtain access to the Personal Information we have collected about you and, where required by law, the right to obtain a copy of the Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
You have the right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
You have a right to ask businesses that use or disclose your sensitive Personal Information to limit those actions to just the CCPA’s Permitted SPI Purposes.
You have the right to request that businesses stop selling or sharing your Personal Information at any time, including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the Personal Information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13.
You have the right to request the deletion of Personal Information that we have collected from you.
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
To submit a request to exercise the Right to Know, Access, Portability, Correction and/or Deletion, please submit a request by:
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to your request. Before processing your request, we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the Personal Information collected in connection with a request, certain requests may require us to obtain additional Personal Information from you. In certain circumstances, we may decline or limit a request, particularly where we are unable to verify your identity.
Only you, or someone legally authorized to act on your behalf, may make a request to know, access, portability, delete, or correct related to your Personal Information. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, access, portability, delete, or correct your Personal Information.
We cannot respond to your request to know, access, portability, delete, or correct if we cannot verify your identity or authority to make the request and confirm the Personal Information relating to you. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make the request.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten-day timeframe, please contact marketing@millwoodinc.com
We endeavor to substantively respond to a verifiable request within 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 to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date.
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 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.
