Last Updated on: March 28, 2022
Effective date: April 1st, 2022
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some its requirements.
1.Information We Collect
Our Websites, which includes Vesync.com, Levoit.com, Cosori.com, and Etekcity.com, (collectively as “Websties,” each a “Website”) 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:
a.Publicly available information from government records.
b.Deidentified or aggregated consumer information.
In particular, our Websites has collected the following categories of personal information from consumers within the last twelve (12) months:
Our Websites obtain the categories of personal information listed above from the following categories of sources:
a.Directly from you. For example, from forms you complete or products and services you purchase.
b.Indirectly from you. For example, from observing your actions on our Websites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
2.Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
a.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.
b.To provide, support, personalize, and develop our Websites, products, and services.
c.To create, maintain, customize, and secure your account with us.
d.To process your requests, purchases, transactions, and payments and prevent transactional fraud.
e.To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
f.To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and via email or text message (with your consent, where required by law).
g.To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
h.For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
i.To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
j.As described to you when collecting your personal information or as otherwise set forth in the CCPA.
k.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 Website users/consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3.Sharing Personal Information
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, Company 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, Company has not sold personal information to the categories of third parties indicated in the chart below.
4.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.
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 (see Exercising Your Rights to Know or Delete), we will disclose to you:
a.The categories of personal information we collected about you.
b.The categories of sources for the personal information we collected about you.
c.Our business or commercial purpose for collecting or selling that personal information.
d.The categories of third parties with whom we share that personal information.
e.If we disclosed your personal information for a business purpose:
·disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
f.The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B personal information.
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 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. Use the personal information internally, in a lawful manner that is 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.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either:
a.Emailing us at firstname.lastname@example.org
b.Mailing us at 1202 North Miller Street, Suite A, Anaheim, CA 92806 US
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child by following the instructions above.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
a.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:
·Items of contact information, or
·Content of communications you sent to us.
·In addition, in the case of a request for specific pieces of personal information, we will ask for an additional piece of information that we may have in addition to the two pieces requested above, together with a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request or an authorized agent acting on behalf of that consumer.
b.An authorized agent or Parent/Guardian seeking to exercise rights on behalf of an individual California resident or their child must prove the agent’s or parent/guardian’s authority either by providing a power of attorney pursuant to Probate Code sections 4121 to 4130 or by:
·Providing a copy of a writing signed by the resident giving the agent permission to act on the resident’s behalf;
·Verification of the authorized agent’s own identity under the procedures in this section; and/or
·Communicating with the California resident directly to confirm the status of the agent as being authorized to act on behalf of the resident.
c.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 relates to you. We will not provide or delete information as requested if we are unable to verify the identity of the requestor as required above, if an agent cannot prove authority to act on behalf of an individual, or we have reason to believe that the request is fraudulent. We may ask for additional verification if we suspect fraud, such as a copy of an identification credential from the requester. We will use any such additional information strictly for identity verification purposes, and it will be deleted following the completion of the verification process. We may, however, retain any information needed to comply with the CCPA or other applicable law.
You do not need to create an account with us to submit a request to know or delete. 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. For California residents with a password-protected account with Vesync accessible via our Websites or our mobile application, we can verify your identity by having you access your account and complete a form to submit a request for your rights or confirm that you made a request.
We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day time-frame, please contact us. See Contact Information below.
We endeavor to substantively respond to a verifiable consumer request within forty-five (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.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your information. However, if you wish to opt out of or stop receiving any marketing communications from us, please contact us at one of the mechanisms listed in Contact Information below. Any email communications from us contain instructions on opting out of further email communications. Nonetheless, even if you opt out of marketing communications, we will still contact you regarding support, administration, and security of our services and products. You can always choose not to provide information, though not providing such information may mean that you may be unable to make a purchase or to take advantage of certain features of our services.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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.
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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
6.Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please see Contact Information below.
Postal Address: 1202 North Miller Street, Suite A, Anaheim, CA 92806 US
Attn: Legal Department
If you need to access this Policy in an alternative format due to having a disability, please contact Privacy@vesync.com.