Last updated September 1, 2021

This California Consumer Act Privacy Notice (“CCPA Notice”) applies to California “Consumers” as defined by the California Consumer Privacy Act (“CCPA”). For the purpose of this CCPA Notice, “Personal Information” (“PI”) as defined by the CCPA includes personal data as used in the Privacy Policy.

This CCPA Notice is in addition to the provisions of the Privacy Policy. In case of contradiction, discrepancy or inconsistency between the Privacy Policy and the CCPA Notice, the CCPA Notice shall prevail for Californian Consumers. We may collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with our Privacy Policy.

We collect the following categories of PI from Consumers: identifiers, personal records, account details, consumer characteristics, professional information, and internet usage information. We draw inferences from PI provided to us by consumers, and use PI provided by Consumers to provide requested products and services; advertise and offer new products and services; and improve our products and services. We share PI provided by Consumers with

(i) our employees that need to have access to your personal data and are authorized to process them in order to achieve the aforementioned purposes and who are committed to confidentiality

(ii) our affiliates’ departments in charge of customer relationship, retail, e-commerce, communication, internal audit, legal, security, and IT management for the purposes set out in this CCPA Notice and our Privacy Policy and to provide you with a consistent level of service across all group companies.

(iii) our service providers who assist us in providing, offering and improving products and services and other purposes (IT development and support; hosting and carrying out marketing and business studies and marketing campaigns; verifying your information, authenticating payments and processing orders and payments, to third parties that provide credit reporting, payment or order fulfilment services; delivery services…).

We also use PI provided by Consumers, along with PI from publicly available data bases and from service providers to prevent fraudulent and illegal activity. We provide such PI to service providers who assist us in preventing fraudulent and illegal activity and in subpoenas and other legal process, who use this PI for such purposes.

We do not “sell” PI that we collect from you, including PI of minors under the age of 16, in accordance with the definition of “sell” in the CCPA, and will treat PI we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies associated with our websites and mobile apps may constitute a “sale” of your PI as defined by the CCPA.

You can exercise control over browser-based cookies by adjusting the settings on your browser. We also list cookies and provide access to their privacy information and, if available, opt-out programs in the Cookie Policy . Further, you can learn more about your choices regarding certain kinds of online interest-based advertising here . We do not represent that these third-party tools, programs or statements are complete or accurate.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell request by you so we currently do not recognize these as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

Consumers have the right to exercise their privacy rights under the CCPA in their individual capacity or via an authorized agent who meets the agency requirements of the CCPA. Authorized agent requests must include a copy of the agency agreement between the authorized agent and the consumer. We will ask the consumer to independently confirm the agency relationship.

We will not discriminate against you in a manner prohibited by the CCPA as a result of your exercising your rights under the CCPA.

Any request you submit to us is subject to a verification process, including without limitation, verification of residency in the State of California (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information to reasonably verify you are the Consumer about whom we collected PI. This verification process includes asking a Consumer to provide two (2) unique data points for disclosure of general categories of PI that we collect. With respect to requests for your specific pieces of PI, as required by the CCPA we will apply heightened verification standards by asking a Consumer to provide three (3) unique data points. To make a Verifiable Consumer Request according to your rights to access your PI or to request deletion of your PI set forth below, you may send us an email to

Some PI we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s PI (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that PI in our response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose and otherwise use and to respond to your CCPA rights requests. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. In addition, we have right not to honor a request to the extent that doing so would infringe upon ours or the rights of any other person of party’s rights or conflict with applicable law.

You have the right to send us a request, no more than twice in any twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting your PI.
  • The categories of third parties to whom we have shared your PI.
  • The specific pieces of PI we have collected about you.
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
  • The categories of your PI we have sold.
  • The categories of third parties to which we sold PI, by categories of PI sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.

Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.

You can read the complete text of our Privacy Policy by clicking here.