Humble Specialty Products, LLC is committed to protecting and respecting your privacy.
This privacy notice explains how we will process any personal information that we may collect about you when you interact with us online (e.g., when you visit or purchase products through this website or interact with us by email) and offline (e.g., when you interact with our customer service representatives by telephone), either as an individual in your own right or when you act on behalf of a company or other organization.
Table of Contents
- Who we are
- Information we collect about you and the sources from which we collect it
- How we use your personal information
- Sharing and international transfer of your information
- Links to other Websites
- Retention and deletion of your information
- Your Choices
- Additional information for individuals in the European Region
- Additional information for California residents
- Contact us
- Changes to this notice
WHO WE ARE
This website is operated by Humble Specialty Products, LLC. In this privacy notice, we refer to Humble Specialty Products LLC. as “Humble,” “We,” and “Us.”
Humble operates this website from the United States of America. If you are visiting the website from another country, you should be aware that the United States of America's data protection and data privacy laws may not be as strict as those in your home country, in particular, if you are visiting our website from within the European Region you should be aware that the United States of America has not been determined to ensure adequate protection for personal information by the European Commission or the other equivalent authorities in the region. We will nonetheless take appropriate steps to protect any personal information that we collect about you.
2. INFORMATION WE COLLECT ABOUT YOU AND THE SOURCES FROM WHICH YOU COLLECT IT
We may collect and process the following information about you:
- Information that you give us: This is information about you that you give to us when visiting our website (for example, when you register with the site or make a purchase) or contact our customer service department by email or telephone. It may include, for example,
- Identifiers including your name, postal address, email address, password, and driver’s license number;
- Other personal information including your age, date of birth, telephone number, fax number, and credit or debit card number;
- Commercial information, including information about products that you purchase or express an interest in purchasing; and
- Professional or employment-related information, including your business contact information, if you register with the site or make a purchase on behalf of a company or other organization.
- Information that our website automatically collects: Our website will automatically collect some information about you and your device, including for example:
- Identifiers including your Internet protocol (IP) address and other information that can be used to recognize you and your device, including cookies and information about your devices such as your browser type and version;
- Internet and other electronic network activity information, including the pages on our site that you visit, the products that you view, and other information about your interactions with our site;
- Inferences are drawn from your activity on our website and information that you give us to create a profile that reflects your product interests and purchasing preferences; and
- Geolocation data, including the geographic location associated with your IP address.
When you use our website, other parties may collect some of this information over time and across different websites, online or cloud computing services, mobile applications, or other online applications to serve you interest-based advertisements on our website or on third-party sites.
- Information we receive from other parties: We may also collect some information about you from other parties, including, for example:
- From our third-party age-verification vendors, identifiers which may include your name and drivers' license number, and other personal information, including your date of birth, including on your driver’s license.
- From operators of third-party websites and other intermediaries who participate in online advertising networks, internet and other electronic network activity information, and inferences drawn from your activity on other websites about your product interests and purchasing preferences.
- From our carriers, identifiers including postal address and other delivery information.
- From credit bureaus, commercial information including credit history information.
We may use your information for the following purposes:
- to make the website available to you and facilitate your use of the website;
- to respond to your inquiries, and provide information that you request;
- to verify your age and identity when you place an order;
- to fulfill orders;
- to process and recover payments for our products;
- to address and resolve customer service and support issues;
- to personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and advertisements, our website and third-party sites;
- to develop and promote our business and our relationship with you or the business you represent, including by communicating with you and any business that you represent via email or text message (with your consent, where required by law) about products that may be of interest to you;
- to administer competitions, promotions and offers that run through our website;
- to operate, administer and improve our website and other aspects of our operations, including debugging, identifying, or repairing errors or effectuating similar functional enhancements;
- to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity on our website, and to prosecute those responsible for that activity;
- to enforce and enable our legal rights and the legal rights of our partners and users;
- to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;
- to comply with our legal and regulatory obligations, including to respond to law enforcement requests and to bring and defend legal claims;
- for administrative and managerial purposes, such as to improve our products and services, informational materials and business practices;
- to engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as for testing, research, analysis, and product development, including to develop and improve our website, products, and services;
- 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 about our customers and/or website users is among the assets transferred; and
- for any other purpose described to you when collecting your personal information before or at the time of collection.
We may from time to time review information about you held in our systems – including our records of your transactions and use of our website – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. These reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve the disclosure of your information to governmental agencies and litigation counter-parties as described below.4. SHARING AND INTERNATIONAL TRANSFER OF YOUR INFORMATION
To accomplish the purposes set out above, we may share personal information about you:
- with our affiliated companies;
- with service providers who perform services on our behalf, and that may include, but are not limited to:
- website hosting and e-commerce platform providers
- data centers
- website analytical service providers (see e.g., Google Analytics https://policies.google.com/technologies/partner-sites),
- online advertising solution providers,
- age verification service providers,
- credit and debit card payment processors,
- order fulfillment and distribution service providers,
- product shipping service providers; and
- marketing companies;
- with any person who takes over our business and assets, or relevant parts of them, as part of a merger, acquisition, bankruptcy, or other transaction; or
- when required by law or necessary to protect our legal interests, with competent regulatory, prosecuting and other governmental agencies, or litigation counter-parties, in any country or territory.
These disclosures may involve transferring your personal information within the United States or overseas, including to other countries that may not have similarly strict data privacy laws as those in your home country. In those cases, where we transfer personal data with other with our affiliate companies or with our service providers, we will ensure that the transfers comply with applicable data privacy laws, including the use of data-sharing agreements as required by law to ensure that your personal information is protected. Please contact us if you would like to know whether any such agreements are in place or if so, to see a copy, as applicable.
Our website may download cookies to your device, and we may also use web beacons to collect information about website usage. A cookie is a data file that is placed by a website operator on the hard drive of a visitor’s computer to their site. A “web beacon” is a transparent graphic image placed on a website that enables the monitoring of things such as user activity and site traffic.
First-party cookies (those placed by Humble) and third-party cookies (those placed by other parties with whom we work) may be placed on your computer when you visit our website to allow our website to function properly and to improve the user experience, including to help you access secure areas or use a shopping cart, to remember you and your preferences as you browse through different pages, and to allow us to perform website analytics.
One of the ways that we do this is through the use of Google Analytics. For more information about how Google Analytics uses and processes data, please visit:
Humble and third parties with whom we work may also place cookies and use web beacons on our website to collect information about your browsing activity, and use that information to deliver content relevant to your interests, including our advertisements, on our website and elsewhere on the internet. We may also use those technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
Our website may include links to other websites and third-party advertising materials. The providers of these websites and materials may collect information about you when you visit/click on them. Humble does not control the personal information processing practices of these provides – you should consult their posted privacy notices.
7. RETENTION AND DELETION OF YOUR INFORMATION
We will delete the information that we hold about you when we no longer need it. Please contact us in writing as specified below for more information regarding our record retention policies and practices.
Note that, if you are a contact at one of our customers, we may retain some limited information about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organization. Generally, we will retain some information after our business relationship with you has ended, so as to maintain an appropriate record of our transactions against the possibility of future disagreements or disputes, or as required by law.
8. YOUR CHOICES
You can adjust your preferences regarding marketing communications.
You may review and request changes to the certain personal information we collect about you. To do so please contact us in writing, as specified below.
At this time, we do not respond to browser "do not track" signals, but you may be able to control and/or delete cookies using the preferences settings in your browser.
In this privacy notice, where we refer to the "European Region", we mean the region comprising the European Union, the other member states of the European Economic Area, Guernsey, Jersey, the Isle of Man and the United Kingdom.
If you are located in the European Region, you may be entitled under the European Union’s General Data Protection Regulation or an equivalent law to certain additional information about, and additional rights with respect to, our collection and disclosure of your personal information. These rights include a right of access to the personal information that we hold about you, and to require any inaccurate personal information to be corrected. You may also have the right to object to our processing of some or all of your personal information, or to require it to be deleted, in some circumstances.
We rely on a variety of legal bases to process your personal information for the purposes set forth above, including as necessary for the pursuit of our legitimate interests in operating, promoting, and improving our website, products, and services, protecting against fraud and other illegal activity, ensuring our compliance with applicable laws, and protecting the security of our website and systems, and as necessary to perform or enter into a contract with you, such as when we collect your payment and shipping information to fulfill orders that you place with us. In exceptional circumstances, we may also be required by law to process your personal information. Finally, we may rely on your consent to process your personal information, for example, if we seek your consent to send you marketing communications. When we process your personal information based on your consent, you may withdraw your consent at any time. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook before the withdrawal. Please contact us in writing as specified below if you wish to exercise any of these rights.
This section of this privacy notice applies only to consumers who reside in the State of California (“consumers” or “you”), and to the personal information of a particular consumer or California household (“California Personal Information”). California Personal Information does not include, and this notice does not apply to, information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”), including information regulated by the Fair Credit Reporting Act. Additionally, this section of the privacy notice applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a “business” under the CCPA.
California Personal Information We Collect
In the preceding 12 months, we may have collected the categories of California Personal Information described in the “Information We Collect About You and the Sources from Which We Collect It” section above.
Disclosures of California Personal Information for a Business Purpose
In the preceding 12 months, we may have disclosed the categories of California Personal Information listed below (which are described in more detail in the “Information We Collect About You and the Sources from Which We Collect It” section above) to the categories of third parties listed below (which are described in more detail in the “Sharing and International Transfers” Section above) for a business purpose:
- Identifiers - with our affiliates and service providers
- Other personal information - with our affiliates and service providers
- Internet and other electronic network activity information – with our affiliates and service providers
- Commercial information - with our affiliates and service providers
- Professional or employment-related information - with our affiliates and service providers
- Inferences - with our affiliates and service providers
- Geolocation information - with our affiliates and service providers
Sales of California Personal Information
In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell the California Personal Information of consumers under 16 years of age.
Your California Privacy Rights
California law provides consumers with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will disclose to you, depending on the scope of the request:
- The categories of California Personal Information we collected about you.
- The categories of sources for the California Personal Information we collected about you.
- Our business or commercial purpose for collecting California Personal Information about you.
- The categories of third parties with whom we shared your California Personal Information.
- The specific pieces of California Personal Information we collected about you.
- If we disclosed your California Personal Information for a business purpose, a list of the disclosures for a business purpose identifying the categories of California Personal Information disclosed.
- Deletion Request Rights. You have the right to request that we delete your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will delete your California Personal Information from our records, unless an exception applies.
- 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 by emailing us at email@example.com
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized representative of that person. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
If you do not have a password-protected account with us we may ask you to provide certain personal information to allow us to verify your identity, which may include name, email address and zip code. We may also use a third-party identity verification service.
You may also submit a request through an authorized representative registered with the California Secretary of State to conduct business in California. Unless you have provided the authorized representative with a power of attorney pursuant to California Probate Code sections 4000 to 4465, the authorized representative must, at the time of submitting the request on your behalf, provide a written permission that you have signed that gives the authorized representative permission to act on your behalf. You must also verify your own identity directly with us, and confirm with that you have provided that permission to the authorized representative.
Any disclosures we provide in response to a request will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized representative. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
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 we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
- Non-Discrimination. You have a right to not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above. Except to the extent permitted by the CCPA, we will not deny you, or charge you different prices or rates for, goods or services or provide a different level or quality of goods or services for exercising the rights described above.
- “Shine the Light” Disclosures. California’s “Shine the Light” law permits California residents who have an established business relationship with us to request certain information regarding our disclosures of their personal information (as defined by that law) during the preceding year, if any, to third parties for those parties’ own direct marketing purposes. If you are a California resident who has an established business relationship with us and wishes to exercise your rights under that law, please send your written request by mail to Humble Specialty Products LLC, Attn: Compliance, 2455 Conejo Spectrum St, Unit 100, Thousand Oaks, CA 91320.
11. CONTACT US
We welcome questions, comments, and requests regarding this privacy statement and our processing of personal information. Please send them to:
Humble Specialty Products, LLC
2455 Conejo Spectrum St, Unit 100
Thousand Oaks, CA 91320
United States of America
You may also email us at firstname.lastname@example.org
If you are located in the European Region, note that you may also be able to lodge a complaint about our processing of your personal information with your local data protection supervisory authority.12. CHANGES TO THIS NOTICE
If there are updates or changes to this privacy notice we will post those changes here and update the Last Revised Date below so that you will always know what information we collect, how we use it, and what choices you have. Your continued use of our website following the posting of changes to this privacy notice means you acknowledge that you have had an opportunity to review those changes.
Issue Date: June 30, 2020
Last Revised Date: June 30, 2020