Sullair’s Privacy Policy for California Residents

Effective Date: January 8, 2021

Last Reviewed On: January 8, 2021

1. Purpose: Sullair, LLC has adopted this policy to supplement the information contained in Sullair’s Privacy Policy and applies to all 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 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
2. Policy: This policy may be modified from time to time without prior notice. Where Sullair collects additional categories of personal information or uses the personal information we collected for materially different, unrelated, or incompatible purposes, Sullair will provide you with notice, post the updated notice here, and update the notice’s effective date. This policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or other similar individuals.
3. Categories of Personal Information: Sullair collects and maintains different types of personal information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”) about consumers in accordance with applicable law. The CCPA sets out eleven categories of personal information and Sullair collects, uses, or otherwise processes the following categories of Personal Information:
   1. Identifiers. For example, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
   2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). For example, a name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, or other financial information.
   3. Commercial information. For example, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
   4. Internet or other similar network activity. For example, browsing history, search history, personal social media activity, personal email, online transactions, information on a consumer’s interaction with a website, application, or advertisement.
   5. Professional or employment-related information. For example, current or past job history.
   6. Inferences drawn from other personal information. For example, profiles reflecting a person’s preferences or characteristics.
4. Collection of Personal Information: Sullair collects Personal Information listed above from the following categories of sources:
   1. Directly from you. For example, from forms you complete or products and services you purchase.
   2. Indirectly from you. For example, from observing your actions on our website.
   3. From third parties. For example, from distributor partners who may provide the information in the performance of a sale or request of information.
5. Uses of Personal Information. In addition to the uses described in Sullair’s Privacy Policy under the section ‘How we use your personal data’, we may use or disclose the Personal Information we collect for one of more of the following purposes:
   1. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
   2. To create, maintain, customize, and secure your account with us.
   3. To process your requests, purchases, transactions, and payments and prevent transactional fraud.
   4. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
   5. To personalize your website experience and to deliver content and product and service offerings relevant to your interests.
   6. To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
   7. For testing, research, analysis, and product development, including to develop and improve our website, products, and services
   8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
   9. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
   10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sullair’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Sullair’s about our customer or users is among the assets transferred.
6. Sharing of Personal Information. We may share your Personal Information by disclosing it to a third party for a business purpose. We strive to 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, Sullair 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. In the preceding twelve (12) months, Sullair has not sold Personal Information.

   Personal Information Category	Category of Third-Party Recipients – Business Purpose Disclosures
   Identifiers.	Service providers providing warranty and maintenance services or replacement parts and with third parties pursuant to contractual obligations.
   California Customer Records personal information categories.	Service providers providing warranty and maintenance services or replacement parts and with third parties pursuant to contractual obligations.
   Commercial information.	Service providers providing warranty and maintenance services or replacement parts.
   Internet or other similar network activity.	Service providers providing IT or website support services.
   Professional or employment-related information.	None.
   Inferences drawn from other personal information.	None.

7. 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. Right to Know and Data Portability. 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 12 months (the "right to know"). Once we receive your request and confirm your identity, to the extent the information exists, we will disclose to you:
      1. The categories of personal information we collected about you.
      2. The categories of sources for the personal information we collected about you.
      3. Our business or commercial purpose for collecting that personal information.
      4. The categories of third parties with whom we share that personal information.
      5. If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
      6. The specific pieces of personal information we collected about you (also called a data portability request).
   2. Right to Delete You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, 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:
      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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.

      We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

   3. Exercising Your Rights to Know or Delete. To exercise your rights to know or delete described above, please submit a request by either:
      • Calling us at 1-800-785-5247.
      • Emailing us at .

      Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please complete the following form or provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. The completed form or other legally binding written document should be emailed to us at . We may also verify the identity of your designated agent.

      You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

      1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, without limitation, your name, your email address, other basic contact or purchase information, and/or the name of any company or employer you have represented in your past dealings with us.
      2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may require that you provide additional information in order to verify your identity and will use all reasonable efforts to honor such requests as quickly as possible and within the time limits set forth by applicable law.

      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.

      You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

8. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
   1. Deny you goods or services.
   2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
   3. Provide you a different level or quality of goods or services.
   4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
9. Changes to Our Privacy Policy. We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the 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.
10. Questions About This Notice: If you have any questions or comments about this notice or the ways in which Sullair collects and uses your information, please contact us via email at , via toll-free telephone at 1-800-785-5247, or via mail at:
    Attention: Compliance
    Sullair, LLC
    North America Operations
    1 Sullair Way
    Michigan City, IN 46360