California Privacy Policy Terms of Use and Guaranetee

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Dirigo Food Safety’s Privacy Policy (collectively, “we,” “us,” or “our”), as well as any other privacy notices we may provide, and applies solely to visitors, users, and others who reside in the State of California (“Consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as amended, and implementing regulations (“CCPA”) and other California privacy laws. Any terms defined in the CCPA, other California privacy laws, or in our Privacy Policy have the same meaning when used in this notice.

A.  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 consumer or device (“Personal Information”). Personal Information does not include (i) publicly available information that is lawfully made available to the general public by way of federal, state, or local government records; (ii) de-identified or aggregated consumer information; and (iii) information excluded from the CCPA’s scope, like: (a) 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, and (b) 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 have collected the following categories of Personal Information from Consumers within the last twelve (12) months:

We obtain the categories of Personal Information listed in the table above from the following categories of sources:

• Directly from You. For example, (i) if you visit our website or register for one of our programs and (ii) if you complete a form or communicate with us through our website.
• Directly from our Clients. For example, from documents or files that our clients provide to us including, but not limited to, information about individuals who may be participating in a program hosted by their employer.
• Directly and indirectly from activity on our websites. For example, from observing your actions on our websites or through your submission of an online form requesting a demonstration or walkthrough for one of our products or services.
• From Third Parties that contract with us or interact with us in connection with the services we perform. For example, from vendors and service providers who assist us with delivering services to you or providing other related services.

B.  Use of Personal Information

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

• To fulfill or meet the reason for which the information is provided. For example, if you provide us or our Service Providers with Personal Information as part of a telephone interaction, through completion and submission of an online registration form on our website, or vendor/partner website, or any other method or means of communication we will: (i) use that information to send you emails, information, and other notices concerning our products or services, or news, that may be relevant to your professional interests, (ii) communicate with you, advertise to you or invite you connect with us or with your peers and with providers of goods and services that may be relevant to your professional interests.
• To provide, support, personalize, and develop our website, products, and services.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
• As necessary or appropriate to protect our rights, property, or safety.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

C.  Sharing or Selling of Personal Information

We may share your Personal Information with other parties, including Service Providers, for a business purpose. When we disclose Personal Information for a business purpose, we enter into 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 will not sell your Personal Information to third parties for any purpose.

1. Sharing Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

• Category A: Identifiers
• Category B: California Customer Records Personal Information categories
• Category D: Commercial information
• Category F: Internet or other similar network activity
• Category G: Geolocation data
• Category I: Professional or employment-related information

We disclose/share your Personal Information with the following categories of third parties for a business purpose:

• Service Providers;
• Data aggregators; and
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

2. Sales of Personal Information to Third Parties

The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales. We do not sell your Personal Information to third parties.

D. 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.

1. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business or commercial purpose for collecting or selling that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific pieces of Personal Information we collected about you (also called a data portability request); and
  • If we disclosed your Personal Information for a business purpose, two separate lists disclosing information about disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

2. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained in our databases, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 Providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using one of the following options:

• Email us at: [email protected]
• Calling us at: 207.517.3920

Only you or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. We will use reasonable methods to verify your request including, for example, comparing the email address you used to register on our website.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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, to the contact information provided in your request. Any disclosures we provide may only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons why we cannot comply with a request, if applicable. For data portability requests, we will endeavor to 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.

5. Personal Information Sales Opt-Out and Opt-In Rights

If you are sixteen (16) years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). Our business is targeted to industry professionals. Therefore, we do not collect or sell the Personal Information of consumers we know are less than sixteen (16) years of age.  If we learn that we have inadvertently collected the Personal Information of someone under the age of 16, we will immediately terminate the associated account and delete any data in connection with such registration and the user’s activity.

E.  Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We may choose in the future to offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites 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 us an electronic message through our website or write us at [email protected].

F.  Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

G.  Contact Information and Accessibility

This notice can be made available in alternate formats upon request. If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:            207.517.3920

Website:        DirigoFoodSafety.com

Email:             [email protected]

Postal Address:
Dirigo Food Safety

Attn: Privacy Inquiry

PO Box 360786

Strongsville, OH 44136

Date:  May, 7 2021