California Consumer Privacy Act (CCPA)




This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of GU USA LLC and its subsidiaries and affiliates (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, 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, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time,“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.  The rights described herein are subject to exemptions under the CCPA and other limitations under applicable laws. 

Personal Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). The following chart lists the categories of personal information we have collected from consumers within the last twelve (12) months.  We may collect all or just a few of these categories with regard to a particular consumer. 
 
CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A 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 card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YES
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).YES
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.YES
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
F. Internet or other similar network activity.Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.NO
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.YES
I. Professional or employment-related information.Current or past job history or performance evaluations.YES
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
K. Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.YES
L. Sensitive Personal InformationGovernment-issued identifiers (such as social security, driver's license, state identification card, or passport number), account log-in and financial information (such as payment card details).YES

Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like: 
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.


We obtain the categories of personal information listed above from the following categories of sources:
- Directly and indirectly from our customers
- Directly and indirectly from activity on our website (www.gu-global.com) and from consumers’ interaction with GU. For example, from submissions through our website portal or website usage details collected automatically.
- From entities that interact with us in connection with the services we perform.
- Government entities and public records
- Publicly available sources aside from public records
- Affiliates and subsidiaries
- Credit reporting agencies, credit and charge card companies, and anti-fraud companies used to process payments and assist with fraud prevention, detection, and mitigation
- Advertising and marketing partners
- Service providers
- Internet or other electronic network activity information and technical information

Last Updated August 1, 2024


 
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