Supplemental Notice for California Residents
This Supplemental Notice for California Residents (“California Supplemental Notice”) is provided by ITW Food Equipment Group LLC (including its subsidiaries and brands, “ITW FEG,” “we,” “us,” or “our”), and contains certain information required under the California Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act of 2020 (collectively, the “CCPA”). This California Supplemental Notice applies to both our online and offline activities involving personal information about California residents and is incorporated into and a part of our Privacy Statement.
Please note that this California Supplemental Notice only applies to residents of California. This California Supplemental Notice does not apply to individuals who are residents of other U.S. states or other countries.
DEFINITIONS
As used in this California Supplemental Notice:
- “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information includes Sensitive Personal Information, but does not include protected health information covered by the Health Information Portability and Accountability Act (“HIPAA”), nonpublic personal information under the Gramm-Leach-Bliley Act (“GLBA”), or any other information which is exempt from the CCPA.
- “Sensitive personal information” includes personal information that reveals, among other things, social security number, driver’s license number, state identification card number, passport number, racial or ethnic origin, union membership, or the contents of a consumer’s mail, email, and text messages (unless ITW FEG is the intended recipient of the communication). Sensitive personal information also includes information concerning an individual’s health, sex life, or sexual orientation.
- “Vendor” means a ‘service provider’ or ‘contractor’ as those terms are defined in the CCPA.
- “Collect,” “Processing,” “Service Provider,” “Contractor,” “Third Party,” “Sale,” “Share,” “Consumer,” and other terms defined in the CCPA and their conjugates, have the meanings afforded to them in the CCPA, whether or not such terms are capitalized herein, unless contrary to the meaning thereof.
COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION
We collect, use, and disclose personal information from and about the following California residents:
- Customers. We collect personal information from and about representatives/employees of our customers, including end users of our B2B service offerings.
- Vendors, Suppliers, and Distributors. We collect personal information from and about representatives/employees of our service providers, contractors, suppliers, and distributors.
- Website Visitors. We collect personal information from and about Website visitors.
Information regarding our California resident personal information practices—including the categories of personal information collected, the sources from which we collect your personal information, the purposes for collecting and disclosing your personal information, and the categories of third parties to whom we may disclose your personal information—is provided below.
Personal Information Collected and Disclosed
The Personal Information Collection and Disclosure Chart below identifies and describes the following:
- The categories of personal information (including sensitive personal information) ITW FEG collected from and about California residents in the preceding 12 months.
- The categories of personal information ITW FEG has sold or shared in the preceding 12 months, if any. For purposes of the CCPA, a “sale” of personal information is the disclosure of personal information to a third party for monetary or other valuable consideration, and the “sharing” of personal information is the disclosure of personal information to a third party for cross-context behavioral advertising , whether or not for monetary or other valuable consideration.
- The categories of personal information ITW FEG has disclosed to third parties for a business purpose in the preceding 12 months, if any. For purposes of the CCPA, a “third party” is any party other than ITW FEG or our Vendors.
- If we have sold, shared, or disclosed to third parties personal information about California residents, the categories of third parties to whom the information was sold, shared, or disclosed.
Personal Information Collection and Disclosure Chart
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PERSONAL INFORMATION COLLECTED |
SOLD OR SHARED? |
DISCLOSED TO THIRD PARTIES? |
CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION IS SOLD, SHARED, OR DISCLOSED |
|
Identifiers, such as real name, alias, postal address, telephone number, email address, other contact information, signature, unique personal identifier, Internet Protocol (IP) address, device or mobile advertising ID, service request ID number, or other similar identifiers. |
YES, shared only; not sold |
YES, shared only; not sold |
|
|
Commercial information, including records of personal property, products or services purchased, obtained or considered, records of program enrollment and activity, or other purchasing or consuming histories or tendencies. |
YES, shared only; not sold |
YES, shared only; not sold |
|
|
Internet or other electronic network activity information, including browsing history, search history, cookie data, referring/exiting URL, clickstream data, time spent on a webpage or advertisement, or other information regarding your interaction with an internet website, application, email or advertisement. |
YES, shared only; not sold |
YES, shared only; not sold |
|
|
Geolocation data, including physical location (based on IP address or similar sources), geofencing data, or device location. |
YES, shared only; not sold |
YES, shared only; not sold |
|
|
Audio, electronic, visual, thermal, olfactory, or similar information, such as customer service call recordings, profile photographs, video testimonials, or device sensor readings. |
YES, shared only; not sold |
YES, shared only; not sold |
|
|
Inferences drawn from any of the information listed in this Personal Information Collection and Disclosure Chart to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. |
YES, shared only; not sold |
YES, shared only; not sold |
|
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CATEGORIES OF SENSITIVE PERSONAL INFORMATION |
|||
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N/A |
N/A |
N/A |
|
We do not have actual knowledge that we sell or share personal information of California residents under 16 years of age.
Sources of Personal Information
We collect personal information directly from our Customers, Vendors, Suppliers and Distributors, and Website Visitors. We also collect personal information from the following sources : our affiliates and other ITW business units; public databases and consumer reporting agencies; industry event sponsors and hosts; your employer; our distributors, suppliers and supply chain partners; joint-marketing partners; advertising companies (like ad servers, advertising agencies, technology vendors, providers of sponsored content, and others); internet service providers; and data analytics providers.
Purposes for Collecting, Selling, Sharing, and Disclosing Personal Information
We, and our Vendors, collect (and, if applicable, sell and share) the categories of personal information identified in the Personal Information Collection and Disclosure Chart (excluding sensitive personal information) for the purposes set forth in our Privacy Statement, as well as for the following purposes :
- Provide you with our products and services
- Fulfilling orders and processing returns
- Customer service
- Send you communications about our products and services
- Register you for a website, program, or event
- Improving our products and services, including improving service delivery and digital content
- Learning about customer trends and interests
- Conduct research, analytics, and data analysis
- Provide advertising or marketing services, including to provide you with targeted ads
- Monitor and improve our website functionality and personalize your website experience
- Manage your Vendor or other business relationship with us
- Provide you access to our systems, networks, databases, equipment, and facilities
- Monitor, maintain, and secure our systems, networks, databases, equipment, and facilities, as well as those of our business partners
- Authenticate your identity and verify your access permissions
- Detect and prevent fraud
- Problem resolution (e.g., internal reviews, grievances), internal investigations, auditing, compliance, risk management and security purposes
- Comply with laws and regulations, including (without limitation) applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws
- Monitor, investigate, and enforce compliance with and potential breaches of ITW FEG policies and procedures and legal and regulatory requirements
- Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons
- Exercise or defend the legal rights of ITW FEG and its employees, affiliates, customers, contractors, partners, and agents
- Facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
We, and our Vendors, collect and use the categories of sensitive personal information identified in the Personal Information Collection and Disclosure Chart only for the following purposes:
- Performing the services or providing the goods reasonably expected by an average Consumer who requests those goods or services (including offering benefits to employees and their beneficiaries);
- Compensation and benefits administration; management of job performance; communication with you/your designated emergency contacts in the event of illness, absence, natural disaster, etc.; authentication of your identity and access to Company systems, networks, databases, confidential information, equipment, and facilities; arranging work-related travel, events, and meetings; assessing fitness for work and other occupational medicine purposes (including work-related injury and illness; filing state or federal government-mandated reports; evaluating diversity and inclusion initiatives; monitoring and securing Company systems, networks, databases, confidential information, equipment and facilities;
- Ensuring security and integrity to the extent the use of the Consumer's Personal Information is reasonably necessary and proportionate for these purposes;
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a Consumer's current interaction with us; provided that we will not disclose the Consumer's Personal Information to a Third Party and/or build a profile about the Consumer or otherwise alter the Consumer's experience outside the current interaction with the business;
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
We do not use or process Sensitive Personal Information for purposes beyond those identified above or as otherwise authorized by the CCPA.
YOUR CALIFORNIA PRIVACY RIGHTS
Rights Available to You
As California resident, you have the following rights regarding our collection and use of your personal information, subject to certain exceptions:
- Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of Collection:
- The categories of Personal Information to be Collected;
- The purposes for which the categories of Personal Information are Collected or used;
- Whether or not that Personal Information is Sold or Shared;
- If we Collect Sensitive Personal Information, the categories of Sensitive Personal Information to be Collected, the purposes for which it is Collected or used, and whether that information is Sold or Shared; and
- The length of time we intend to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.
We have provided such information in this California Supplemental Notice, and you may request further information about our privacy practices by contacting us as set forth in the Contact Us section below.
- Right to Know Personal Information Collected; Right to Access Personal Information: You may request that we provide you with the following:
- The categories of Personal Information we Collected about you;
- The categories of sources from which we Collected such Personal Information;
- The business or commercial purpose for Collecting, Selling, or Sharing Personal Information about you;
- The categories of Third Parties with whom we disclosed such Personal Information; and
- The specific pieces of Personal Information we have Collected about you.
- Right to Know Information Personal Information Sold or Shared: You may request that we disclose to you:
- The categories of Personal Information that we have Collected about you;
- The categories of Personal Information that we have Sold or Shared about you and the categories of Third Parties to whom the Personal Information was Sold or Shared; and
- The categories of Personal Information we have disclosed about you for a business purpose and the categories of Third Parties to whom it was disclosed for a business purpose.
- Right to Deletion: You may request that we delete any Personal Information about you that we Collected from you.
- Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.
- Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights.
- Rights to Opt-Out of the Sale and Sharing of Your Personal Information and to Limit the Use of Your Sensitive Personal Information: You have the right to opt-out of the Sale and Sharing of your Personal Information. You also have the right to limit the use of your sensitive personal information to the purposes authorized by the CCPA.
We sell and/or share personal information about California residents as set forth in the Personal Information Collection and Disclosure Chart above. You have the right to opt-out of the sale and/or sharing of your personal information. To submit an opt-out request, please access the below link or contact us as set forth in the Contact Us section below. We will process your request(s) in accordance with applicable law.
[“Do Not Sell or Share My Personal Information” Link]
Exercising Your Rights (talk to James about form, note)
You may exercise your privacy rights by contacting us as set forth in the Contact Us section below or by clicking [here]. You may also authorize an agent to make a request on your behalf, and the authorized agent may do so via the listed submission methods.
Verification of Your Requests
We may ask you to provide information that will enable us to verify your identity in order to comply with your request. In particular, if you authorize an agent to make a request on your behalf, we may require the agent to provide proof of signed permission from you to submit the request, or we may require you to verify your own identity to us or confirm with us that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under the CCPA. We will respond to your request consistent with applicable law.
CONTACT US
If you have any questions regarding our Privacy Statement (including the California Supplemental Notice) or ITW FEG’s collection, use and disclosure of your personal information, or would like to exercise your privacy rights, please contact us at the information below or click [here]. If you are unable to review or access our Privacy Statement (including the California Supplemental Notice) due to a disability, you may contact us to access our Privacy Statement (including the California Supplemental Notice) in an alternative format.
ITW Food Equipment Group
Attn: Digital Marketing Services
701 S. Ridge Avenue
Troy, OH 45373
Toll-Free (USA): (800) 777-2828
websupport@itwfeg.com
Email: privacy@itw.com (ask James if we can use this or is it just an example)
Last Revised: November 1, 2023
