SCOPE OF SUPPLEMENTAL NOTICE
This Notice provides additional information about how we collect, use, disclose, and otherwise process personal information of residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA").
COLLECTIONUSE, AND DISCLOSURE OF PERSONAL INFORMATION
We may collect, transmit, and store “personal information” about you in connection with your use of the Fortero Site. When we use the term "personal information" in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. Personal information does not include publicly available information made lawfully available by state or federal governments or de-identified information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked directly or indirectly to a particular individual.
Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Pursuant to the CCPA, we may collect and disclose for a business purpose, and may have done so in the prior 12 months, the following categories of personal information (as defined by the CCPA):
- Identifiers: such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Customer records (i.e., categories of personal information set forth in Cal. Civ. Code 1798.80(e)): such as 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 or debit card number, other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California or federal law: such as race, religion, sexual orientation, gender identity, gender expression, or age.
- Commercial information: such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information: such as hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data.
- Internet or other electronic network activity information: such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
- Geolocation data: such as precise location information about a particular individual or device.
- Audio, electronic, visual, thermal, olfactory, or similar information: such as CCTV footage, photographs, and audio recordings.
- Professional or employment-related information: such as work history and prior employers.
- Education information: such as information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
- Inferences from personal information collected: Inferences drawn from any of the information identified above to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
SOURCES OF PERSONAL INFORMATION
The sources from which we collect personal information depend on, among other things, our relationship or interaction with a specific California resident. The categories of sources from whom we collect this personal information are:
- Directly from California residents, or other individuals acting on their behalf, through physical (e.g., paper application), audible (e.g., phone), or electronic (e.g., website, social media) sources.
- Automatically through your access or use of the Fortero Site, including through your interaction with us or the Fortero Site.
- Service partners and providers, contractors, vendors, advertisers, and other third parties.
- Information provided by our affiliates and subsidiaries.
To Whom We Disclose Personal Information
The categories of third parties with whom we share personal information depend on, among other things, our relationship or interaction with a specific California resident. The categories of third parties to whom we disclosed personal information for our business purposes described in this Notice are:
- Affiliates and subsidiaries of Fortero.
- Service partners and providers, contractors, vendors, advertisers, and other third parties who provide services such as website hosting, storage, data analysis, payment processing, order fulfillment, shipping, information technology and related infrastructure, customer service and communications, email delivery, auditing, advertising and marketing, and marketing research activities.
- Other third parties who enable customers to conduct transactions online and via mobile devices.
- Government agencies as required by laws and regulations.
Use of Personal Information
The purposes for which we collect and use personal information depend on, among other things, our relationship or interaction with a specific California resident. In the past 12 months, we have used personal information relating to California residents to operate, manage, and maintain our business, and to accomplish our business purposes and objectives, including the following:
- To perform various services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.
- To enable your access to and use of our products, goods, and services and the Fortero Site features, as well as to allow you to participate in interactive features of the Fortero Site when you choose to do so.
- To create and manage your account with Fortero.
- To personalize your experience and to allow us to deliver the type of content, advertising, and offerings in which you are most interested.
- To undertake activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- To provide, maintain, protect, develop, and improve the Fortero Site, and to notify you about changes to the Fortero Site.
- To fulfill your requests for products, goods, and services, and process and deliver your transactions and orders.
- To deliver gift cards.
- To provide you with information in response to your inquiries, and to provide you with customer support.
- To administer contests, sweepstakes, promotions, surveys, or other Fortero Site features.
- To send periodic SMS messages regarding your order(s), including shipping and delivery updates.
- To send periodic emails regarding your order or other products, goods, and services.
- To email you information about the Fortero Site.
- To mail information about the Fortero Site, marketing materials, and gifts to you.
- To offer you additional information, opportunities, promotions, and functionality from us or on our behalf.
- To assist us in taking data security precautions, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- To detect, prevent, and address technical issues.
- To debug, identify, and repair errors that impair existing intended functionality.
- To undertake internal research for technological development and demonstration.
- To comply with applicable international, federal, state, provincial and local laws, directives, rules, regulations, and ordinances; civil, criminal or regulatory investigations; or other legal requirements, such as court orders.
NO Sale of Personal Information
In the past 12 months, we have not “sold” personal information subject to the CCPA, including personal information of minors under the age of 16. For purposes of this disclosure, “sold” means the disclosure of personal information to a third party for monetary or other valuable consideration. We do not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt out of such sale as required by law.
YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
- The Right to Know. You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information we have collected about you;
- The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold about you, and the categories of third parties to whom this information was sold; and
- The business or commercial purposes for collecting or selling personal information about you.
- The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
- The Right to Opt Out of Personal Information Sales. You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
- The Right to Non-Discrimination. As a California resident, you have the right not to receive discriminatory treatment for exercising any of the rights described above. We will not discriminate against you for exercising any of your CCPA rights and we will not deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to engage with you in the same manner.
How to Exercise Your California Privacy Rights
- To Exercise Your Right to Know or Your Right to Request Deletion. To exercise your right to know and your right to request deletion, please submit a request by:
- Calling us toll free at: (855) 679-1471; or
- Emailing firstname.lastname@example.org with the subject line "California Rights Request"; or
- Writing to us at the following address:
Seiseidou America, Inc. dba Fortero
Attn: Website Administrator – Data Privacy
10880 Wilshire Blvd. Suite 1101
Los Angeles, California 90024, U.S.A.
We will need to verify your identity before processing your request. 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 to exercise the right to know and the right to request deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or the right to request deletion, particularly where we are unable to verify your identity.
- To Exercise Your Right to Opt Out of Personal Information Sales; Do Not Sell My Info. We do not currently and will not sell in the future (as the term “sell” is defined in CCPA) any personal information without providing you with notice and an opportunity to opt out of such sale as required by law.
- Authorized Agent. In certain circumstances, you are permitted to use an authorized agent registered with the California Secretary of State to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
Non-affiliated third parties are independent from us, and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.
NOTICE OF Financial Incentives
We may offer incentives in exchange for the retention of personal information.
We may also hold contests, sweepstakes, or provide special offers to users who have elected to let us contact them by email, text messaging, direct messaging, and/or through social media. Participation is voluntary, and users always have the option to not supply information and/or to opt out.
“Shine the Light” LAW
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s "Shine the Light" law (Civ. Code § 1798.83) Under the “Shine the Light” law, California residents who provide certain personal information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
California's "Do Not Track" Notice; THIRD PARTY BEHAVIORAL TRACKING.
We may update this Notice from time to time. When we make changes to this Notice, we will change the "Last Updated" date at the beginning of this Notice. If we make material changes to this Notice, we will notify you by email to your registered email address, by prominent posting on our online services, or through other relevant communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Seiseidou America, Inc. dba Fortero
Attn: Website Administrator – Data Privacy
10880 Wilshire Blvd. Suite 1101
Los Angeles, California 90024, U.S.A.