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Privacy Notice for California Residents

Last Updated: December 12, 2023


This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the Snow Peak USA (“Us” or “Snow Peak”) Privacy Policy (located here]) and applies solely 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 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”) (together, the “California Privacy Laws”) and any terms defined in the CCPA have the same meaning when used in this Notice. To the extent this Notice contradicts California Privacy Laws or other applicable laws, the law controls. We do not sell personal information, including any sensitive personal information, we collect about you.

Information We Collect

We collect 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, household, or device (“personal information”). 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”), clinical trial data, or other qualifying research data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

 

Personal Information Category

Retention Period

Business Purposes

Identifiers, such as your real name, postal address, Internet protocol (“IP”) address, email address, account name, or other similar identifiers.

As required by law or as long as necessary for a business purpose, whichever is longer.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To create, maintain, customize, and secure your account with us.

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 website, products and services, databases and other technology assets, and business.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

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 about our consumers is among the assets transferred.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

California Customer Records employment and personal information, such as your name, address, telephone number, and credit card number.

*Some personal information included in this category may overlap with other categories.

As required by law or as long as necessary for a business purpose, whichever is longer.

Same as the identifiers category directly above.

Protected classification characteristics under California or federal law, such as 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).

As required by law or as long as necessary for a business purpose, whichever is longer.

We only collect this information if voluntarily provided (for example, in the other notes section of a reservation form or via a product review). 

Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

As required by law or as long as necessary for a business purpose, whichever is longer.

To personalize your Website experience.

For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

To provide, support, personalize, and develop our Website, products, experiences, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Internet or other similar network activity, such as browsing history, search history, and information on your interactions with our Website.

 

As required by law or as long as necessary for a business purpose, whichever is longer.

To personalize your Website experience.

To provide, support, personalize, and develop our Website.

To help maintain the safety, security, and integrity of our Website, databases and other technology assets, and business.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

Geolocation data.

As required by law or as long as necessary for a business purpose, whichever is longer.

To provide, support, personalize, and develop our Website, products, experiences, and services.

 

Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information.

As required by law or as long as necessary for a business purpose, whichever is longer.

We collect footage from cameras in the common areas of our Campfield locations only to maintain the safety and security of our camping experiences and reservation guests.

Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

As required by law or as long as necessary for a business purpose, whichever is longer.

To provide, support, personalize, and develop our Website, products, experiences, and services.

 

Sensitive Personal Information

Sensitive personal information (“SPI”) is a subtype of personal information consisting of specific information categories. In particular we collect the following categories of SPI from you:

SPI Category

 

Retention Period

Business Purpose

Complete account access credentials, such as user names, account numbers, or card numbers combined with required access/security code or password.

As required by law or as long as necessary for a business purpose, whichever is longer.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To create, maintain, customize, and secure your account with us.

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 Website, products and services, databases and other technology assets, and business.

Precise geolocation, such as your physical location within a small area (1,850 feet radius).

As required by law or as long as necessary for a business purpose, whichever is longer.

To provide, support, personalize, and develop our Website, products, and services.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Website.

Use Of Personal And Sensitive Personal Information

We will not sell the personal information or SPI we collect. We may disclose your personal information to our third party service providers for a business purpose. We will not collect additional categories of personal information or SPI or use the personal information or SPI we collected for materially different, unrelated, or incompatible purposes without providing you notice. For more information on how we may use or disclose the personal information we collect, please see our Privacy Policy.

Your Rights And Choices

California Privacy Laws provide California residents with specific rights regarding their personal information and SPI. This section describes your rights and explains how to exercise those rights.

 

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 and SPI over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Your Rights to Know or Delete), we will disclose to you:

  • The categories of personal information and SPI we collected about you.
  • The categories of sources for the personal information and SPI we collected about you.
  • Our business or commercial purpose for collecting that personal information or SPI.
  • The categories of third parties with whom we share that personal information and SPI.
  • If we 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.

The specific pieces of personal information and SPI we collected about you (a “data portability request”).


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 (see Exercising Your Rights to Know or Delete), we review your quest 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.

Exercising Your Rights to Know or Delete

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

Only you, or someone legally authorized to act on your behalf, may make request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. You request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or SPI or are 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 or SPI 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.


Response Timing and Format

We will confirm receipt of your request within 10 business days.

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your California Privacy Law rights. Unless permitted under the California Privacy Laws, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Contact Information

If you have any questions or comments about this Notice, or need to access this Notice in an alternative format due to having a disability, please contact us by email at info@snowpeak.com