California privacy policy

California Privacy Policy


Effective Date: July 1, 2020

This California Privacy Policy for California residents ("California Privacy Policy") is provided by The a2 Milk Company (“a2MC” “we,” “us,” or “our”), and applies solely to the Personal Information (as defined below) that we collect and use relating to consumers and users who reside in California ("you," "consumer," or "customer"). This California Privacy Policy supplements our general privacy policy and is parallel in scope to our privacy policy. We provide this California Privacy Policy to comply with California privacy laws, including the California Consumer Privacy Act of 2018, as amended ("CCPA"), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

 

Definitions Specific to this Policy

The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to a2MC’s privacy policy, including the following terms:

“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 consumer or household. Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.

“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.

“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.

 

The Personal Information We Collect and Disclose

The chart below shows the categories of Personal Information we may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purpose(s) for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, we disclose certain Personal Information to third parties for a business purpose. We also sell or share certain Personal Information to third parties. We do not sell the personal information of minors under 16 years old without affirmative authorization. This information covers the past 12 months.

 

   

   
Categories of Personal Information    
   

   
Examples    
   

   
Types of Sources from which this Category of Personal   Information Is Collected    
   

   
Business Purposes for Collection    
   

   
Types of Third Parties with Whom this Category of   Personal Information Is Shared/Sold and/or   Disclosed    
   

   
Unique identifiers    
   

   
Name, signature, address, telephone email, account   name, online identifier, IP address
   

   

   

   

   

   

   

   

   

   
   
   

   
-Directly from you by telephone, our websites, our   mobile apps, in-person
   
-Social media
   

   
Other individuals
   
-Customer accounts
   
-Analytics providers
   
-Vendors
   
-Business partners
   

   
   
   

   
-Security and fraud prevention
   
-Provide customer service and assess satisfaction
   
-Personalize customer experience
   
-Improve products and services
   
-Improve marketing and customer communications
   
-Comply with legal requirements    
   

   
Disclosed:
   
-Vendors
   
-Licensors
   
-Manufacturers -Affiliates
   
-Business Partners
   

   
Shared/Sold:
   
-Online analytics providers
   
-Online advertisers    
   

   
Purchase history    
   

   
Commercial information, including records of personal   property, products or services purchased, obtained,   or considered, or other purchasing or consuming histories or   tendencies    
   

   
-Directly from you by telephone, our websites,   in-person
   
-Other individuals
   
-Vendors
   

   
   
   

   
-Complete transactions
   
-Customer communication related to goods and services
   
-Dispute resolution
   
-Process claims
   
-Marketing communications
   
-Operate our systems    
   

   
Disclosed:
   
-Vendors
   
-Licensors
   
-Manufacturers -Affiliates
   
-Business Partners
   

   
Shared/Sold:
   

   
-Online analytics providers
   

   
-Online advertisers    
   

   
Internet activity    
   

   
Internet or other electronic network activity   information, including, but not limited to, browsing history,   search history, and information regarding a consumer’s   interaction with an Internet Web site, application, or   advertisement    
   

   
-Directly from you by telephone, our websites, in-person
   
-Social media
   

   
   
   

   
-Provide customer service and assess satisfaction
   
-Personalize customer experience
   
-Improve products and services -Improve marketing and   customer communications
   
-Comply with legal requirements    
   

   
Disclosed:
   

   
-Vendors
   
-Agencies
   
Shared/Sold:
   
-Online analytics providers
   
-Online advertisers
   

   
   
   

   
Geolocation data    
   

   
Geolocation data    
   

   
-Our websites, in-person
   

   
   
   

   
-Provide customer support
   
-Offer relevant services    
   

   
Disclosed:
   
-Vendors
   
-Agencies
   

   
Shared/Sold:
   
-Online analytics providers
   
-Online advertisers    

 

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Information Collection

 You have the right to request certain information regarding the Personal Information we have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.

  • If you would like to request (1) specific pieces and the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom we have shared that Personal Information; and/or (4) the business purposes for collecting, using and sharing that Personal Information, please use the Contact Us form and describe your request.

 

Verification Process

After we receive your request, to ensure the security of the information we store and consumers’ privacy, we will verify that you are appropriately affiliated with the subject of the request, either as the consumer or as an authorized agent or guardian of the consumer. We may ask you to provide a few pieces of information to confirm your identity in our records.

We will only send CCPA verification questions from hello@a2milk.com. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our CCPA verification email address listed above, do not respond.

Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.

 

Financial Incentives and Non-Discrimination

We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

However, we may provide financial incentives to consumers who allow us to retain and disclose their Personal Information. These incentives may include payments to consumers for winning a contest, a lower price for goods or services, and/or a higher level of goods or services. You may withdraw from the incentive at any time.

The incentives we provide are as follows:

  • Gift cards, prizes, and giveaways

The categories of information we collect through incentives include first name, last name, email address, and mailing address.

Our incentive is permissible under the CCPA because we use incentives to raise awareness of our great products. We estimate that value at $13,500 per year, and arrived at that figure by estimated value of incentives.

 

Deletion of Your Personal Information

 You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.

  • If you would like to request that we delete your Personal Information pursuant to the requirements of the CCPA, please use the Contact Us form and describe your request.

 

Authorized Agents

You may designate an authorized agent to exercise your rights under the CCPA on your behalf.

Pursuant to the CCPA:

  • Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
  • You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
  • We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by the CCPA.
  • Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided with a power of attorney under California Probate Code sections 4000 to 4465.

 

Personal Information of Minors

We are proud of our online information and we strive to ensure we do not offend people of any age. However, our web pages are not intended for children or minors under the age of sixteen years. Accordingly, we do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to Us, please use the Contact Us form and we will delete the information.

 

Right to Opt-Out

You have the right to request that we do not sell Personal Information that we have collected.

  • If you would like to request that we do not sell your Personal Information pursuant to the requirements of the CCPA, please use the Contact Us form and describe your request.
  • If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.

 

Additional Information

If you would like additional information regarding our California Privacy Policy, please use the Contact Us form and describe your request.

 

Additional California Privacy Rights

California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to hello@a2milk.com with the subject “Shine the Light Request.”

 

Changes to Our California Privacy Policy

a2MC reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.