Kool California Privacy Notice

Updated: Effective January 1, 2022

This Kool (“Kool,” “Company,” “us,” “we,” or “our”) California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (the “CCPA”). This Notice supplements Kool’s other privacy policies and notices, including our main Privacy Policy. In the event of a conflict between any other Company policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under the CCPA.

Consistent with the CCPA, the information in this Notice and the rights described do not apply to job applicants, current and former employees/contractors, or to people whose Personal Information we collected in the context of their employment at another business (“business-to-business contact(s)”). If you are an employee, job applicant, or business-to-business contact and you have questions about how we use your Personal Information, please contact us as provided below.

1. Personal Information We Collect & Why We Collect It

   “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

   Within the past 12 months, we collected the following categories of Personal Information about California consumers. Note that the specific pieces of Personal Information we collected about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

   Category of Personal Information	Examples	Purposes for collection
   1. Identifiers	Name, title, alias, postal address, phone number, email address, online identifier, username and password for our Service, security question/answer combinations, IP address, mobile device identifiers, social media usernames, state ID card number	To allow you to participate in the features we offer on the Service To maintain your accounts with us To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback To send you marketing materials and advertisements To recognize you when you use our Service To show you relevant ads while you browse the internet or use social media To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us
   2. Personal Records Described in Cal. Civ. Code § 1798.80(e)	Name, signature, address telephone number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or other financial information Some Personal Information included in this category may overlap with other categories	To allow you to participate in the features we offer on the Service To maintain your accounts with us To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback To send you marketing materials and advertisements To recognize you when you use our Service To show you relevant ads while you browse the internet or use social media To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us
   3. Protected classification charactersitics under California or federal law	Age, birth date, gender, languages spoken	To allow you to participate in the features we offer on the Service To send you relevant marketing materials and advertisements To tailor our communications to you To improve the Service, and our products, marketing and advertising Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us
   4. Commercial Information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, purchase channel (online or retail), communication channel preferences, coupon and loyalty program usage, information from surveys, promotions and product reviews	To allow you to participate in the features we offer on the Service To provide you with appropriate products and recommendations To help you find relevant products more quickly To tailor our communications to you To provide customer service and support To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs To improve the Service, and our products, marketing and advertising Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us
   5. Internet or other electronic network activity information	Browser type and language, operating system, internet or mobile network provider, website access time, duration of visit, referring website address, browsing and search history on our websites, webpages viewed immediately before and after our websites, information related to your interactions with our websites, social media pages, emails, online chat, text message communications, and advertisements	To allow you to participate in the features we offer on the Service To facilitate, manage, personalize, and improve your website or app experience To provide you with appropriate products and recommendations To show you relevant ads while you browse the internet or use social media To improve the Service, and our products, marketing and advertising To send you relevant coupons To allow you to participate in promotions, sweepstakes, contests, and rewards programs Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us
   6. Geolocation Data	Your physical location based on information you provide directly or inferred from your IP address	To allow you to participate in the features we offer on the Service To deliver coupons to you Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
   7. Audio, electronic, visual, thermal, olfactory, or similar information	Audio recordings of customer care calls, video, or similar information	To provide you with customer service To improve our products and the Service
   8. Inferences from other Personal Information	Your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes based on other Personal Information collected about you	To provide you with appropriate products and recommendations To improve the Service, and our products, marketing and advertising To provide you with a better website or app experience Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes To detect and prevent fraud against you and/or us

   We may also collect Personal Information about you that does not directly fit within one of the categories defined by the CCPA. For example, we collect the contents of communications you send to us by phone, email, text, online chat, etc. We use the information included in your communications to communicate with you about our products and services, your orders, updates to our terms and policies, and to obtain your feedback; to provide customer service and support; to improve our website, apps, products, and marketing; to allow you to participate in our promotions, sweepstakes, contests, and loyalty programs; and to detect and prevent fraud against you and/or us.

2. Sources of Personal Information

   We may collect your Personal Information directly from you when you provide us information online, through electronic forms, over the phone, or through paper documents; automatically through our websites via cookies and other tracking technologies; from our service providers, vendors and suppliers, our affiliates, or other individuals and businesses; from third-party sources, such as data providers; and from public sources of data, such as government databases. More detail on the ways in which we collect Personal Information can be found in our Privacy Policy.

3. Disclosures & Sales of Personal Information

   We share Personal Information with our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), affiliates, and third parties.

   Generally, we disclose the following categories of Personal Information for a business purpose:

   1. Identifiers
   2. Personal records described in Cal. Civ. Code § 1798.80(e)
   3. Protected classification characteristics
   4. Commercial information
   5. Internet or other electronic network activity information
   6. Geolocation data
   7. Audio, electronic, visual, thermal, olfactory, or similar information
   8. Inferences

   The categories of persons to which we disclosed this Personal Information include affiliated and related companies, service providers, professional advisors, public authorities/government bodies, and external auditors. More information on how we share Personal Information can be found in our Privacy Policy.

   Although we do not sell Personal Information in exchange for money, some of the ways in which we share Personal Information for advertising or marketing may be considered “sales” under California law. The categories of Personal Information we “sell” are:

   1. Identifiers
   2. Commerical information
   3. Internal or other electronic network activity information
   4. Geolocation data

   The categories of persons to which Personal Information is sold include third parties for co-marketing purposes or to promote other products and services that may interest you; advertising partners and social media platforms for the purposes of ad targeting, remarketing, and customized advertising content; and data cooperatives, exchanges, and data brokers.

   We do not knowingly collect or sell the Personal Information of persons under the age of 21.

4. California Privacy Rights

   California residents have the right to submit certain requests relating to their Personal Information as described below. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.

   To submit a request, please user our Consumer Rights Request form or call (888) 342-6567.

   1. The Right to Know

      If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:

      1. The categories of Personal Information we have collected about you
      2. The categories of sources from which the Personal Information was collected
      3. Our business or commercial purposes for collecting (or selling—if applicable) your Personal Information
      4. The categories of third parties with which we shared your Personal Information
      5. The categories of Personal Information about you that we sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
      6. The categories of Personal Information that we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
      7. The specific pieces of Personal Information we have collected about you

      You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

   2. Right to Opt Out of "Sales" of Personal Information

      Although we do not sell your Personal Information in exchange for money, some of the ways in which we share your Personal Information for advertising or marketing may be considered a “sale” under California law. If you are a California resident and would like to opt out of our use of your information for these purposes, you may do so by submitting a request through our webform or by downloading and using a browser supporting the Global Privacy Control (GPC) browser signal. If you choose to use the GPC signal, you will need to turn it on for each browser you use.

   3. Right to Delete

      You may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will let you know what Personal Information we can delete from our records, and we will direct any of our service providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to complete a transaction or provide services to you; (2) keep you enrolled in our rewards program; (3) for purposes of a product warranty or recall; (4) detect security incidents; (5) protect against unlawful activities; (6) identify, debug or repair errors; or (7) comply with a legal obligation. You may submit a request to delete as described at the beginning of Section 4. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

   4. Non-Discrimination

      You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

5. Third-Party Marketing

   Separate from your CCPA rights, you may obtain a list of the third parties to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for third-party direct marketing purposes. To submit a request, please email us at privacy@itgbrands.com or send a letter to us at 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department). Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

   Separate from your CCPA rights, you may obtain a list of the third parties to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for third-party direct marketing purposes. To submit a request, please email us at privacy@itgbrands.com or send a letter to us at 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department). Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

6. How to Contact Us

   For more information on your California privacy rights, please contact us here, by mail to 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department), or by phone at 1 (888) 342-6567.