Privacy Policy for California Residents

We may collect, and in the last twelve (12) months have collected, the following categories of personal information from Consumers:

Category	Examples
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.
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.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
I. Professional or employment-related information.	Current or past job history or performance evaluations.
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may collect your personal information from the categories of sources of personal information identified in our Privacy Policy. For the sake of clarity, these categories may include: you directly, advertising networks, data analytics providers, and social networks.

We may collect, use, maintain, disclose, and otherwise process your personal information for the business and/or commercial purposes identified in our Privacy Policy.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Sound Devices has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information.

Personal Information Category	Category of Third-Party Recipients
	Business Purpose Disclosures	Sales
A: Identifiers.	Service Providers Internet cookie data recipients, like Google Analytics.	None
B: California Customer Records personal information categories.	Service Providers Internet cookie data recipients, like Google Analytics.	None
D: Commercial information.	Service Providers	None
F: Internet or other similar network activity.	Service Providers Internet cookie data recipients, like Google Analytics.	None
I: Professional or employment-related information.	Service Providers	None
K: Inferences drawn from other personal information.	Service Providers	None

The CCPA provides Consumers with certain rights regarding their personal information. This section describes these rights and explains how Consumers may exercise them.

Right to Know; Data Access and Portability Requests

You have the right to request that we disclose certain information (the “Right to Know”) to you about our collection, use, disclosure, of your personal information over the past twelve (12) months (a “Request to Know”).

Once we receive and verify your Request to Know (see Exercising Access, Data Portability and Deletion Requests), we will disclose to you each of the following items which you include in your Request to Know:

• The categories of personal information we have collected about you;
• The categories of sources for the personal information we have collected about You;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we have shared that personal information;
• The specific pieces of personal information we have collected about you; (if delivered to you electronically in a portable format, a “Data Portability Request,” if delivered to you by other means, a “Data Access Request”);
• If we have sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

For information on how to submit a Request to Know, Data Access Request, or Data Portability Request, see Exercising Access, Data Portability and Deletion Requests.

The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B Information”) from some of its requirements. To the extent permitted by the CCPA, we may deny a Request to Know, Data Access Request, or Data Portability Request relating to B2B Information.

Right to Opt-out of the Sale of Personal Information

You have the right to direct a business to not sell your personal information at any time (the “Right to Opt-Out”). However, we do not sell the personal information of Consumers, including Consumers we actually know are less than sixteen (16) years old.

Right to Request Deletion

You have the right to request that we delete any of your personal information that we have collected from you or have maintained or retained, subject to certain exceptions (a “Request to Delete”). Once we receive your request and confirm your identity (see Exercising Access, Data Portability and Deletion Requests), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• 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.
• Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To the extent permitted by the CCPA, we may deny a Request to Delete relating to B2B Information.

Right to Non-Discrimination

You have the right to not receive discriminatory treatment for your exercise of privacy rights under the CCPA, by, for example, being denied goods or services or being charged different prices for goods or services because of your exercise of CCPA rights.

Unless permitted by the CCPA, we will not do any of the following based upon your exercise of privacy rights under the CCPA: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Authorized Agents

You may authorize another person (an “Authorized Agent”) to exercise any of your rights under the CCPA. To designate an Authorized Agent to make a request with us, (i) provide the authorized agent signed permission to submit a request under this Policy with us, and (ii) confirm with us that you provided the Authorized Agent permission to submit the request by submitting such signed permission to us by email at [email protected]. Please note that you may be required to verify your identity prior before your confirmation of permission for the Authorized Agent is effective under this Policy.

Exercising Access, Data Portability and Deletion Rights

To exercise the access, data portability, and deletion rights described in this Policy, please submit a verifiable consumer request to us by either:

• Calling us at 1-800-505-0625.
• Emailing us at [email protected].

Only you or your Authorized Agent may make a verifiable consumer request related to your personal information. You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a twelve (12) month period. Your Request to Know, Data Access Request, or Data Portability 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 of such person, which may include:

• Information which we already maintain; or
• If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within this timeframe, please contact us as provided below. 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. If we cannot verify your request within 45 days from the date that we receive your request, we may deny your request.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

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.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Other California Privacy Rights

California’s “Shine the Light” law (Cal. Civil Code § 1798.83) permits Consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not currently disclose personal information to third parties for their direct marketing purposes.

We reserve the right to amend this policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on our Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:	1-800-505-0625
Email:	[email protected]
Postal Address:	ATTN: Data Protection Sound Devices, LLC E7556 State Road 23/33 Reedsburg, WI 53959