GEO HOLDINGS CORPORATION

CCPA Praivacy Policy

If you are a resident of California, please see Appendix A for information regarding our use of your personal information.

APPENDIX A: CALIFORNIA PRIVACY RIGHTS

Effective: July 1st, 2021

Your California Privacy Rights:

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and certain other privacy and data protection laws, as applicable, residents of California have the right to request that we disclose what personal information we collect, use, disclose, and sell. More specifically, if you are a resident of California you have rights to the following without charge:

Disclosure of Personal Information We Collect About You
You have the right to know the categories of personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, if any, and the specific pieces of personal information we have collected about you.

We reserve our rights to (i) not retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about consumers is not retained; (ii) not reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; and (iii) not provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Used for a Business Purpose
In connection with personal information we may sell or disclose for a business purpose, if any, you have the right to know the categories of personal information about you that we sold and the categories of third parties to whom we sold the personal information, and the categories of personal information that we disclosed about you for a business purpose.

Deletion of Personal Information
Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers to delete your personal information from their records.

We are not required to, and reserve our right to not delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act; (vi) 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us; (viii) comply with an existing legal obligation; and (ix) otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Freedom from Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the California Consumer Privacy Act. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please or submit your request to us at 800-592-9740 or at 2ndstreetusa_official@2ndstreetusainc.com with the subject “CCPA Consumer Request.”

In order to verify your request, you will need to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates.

You may also designate an authorized agent to make a request under the California Consumer Privacy Act on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Your Right to Opt-Out of the Sale of Personal Information

We do not sell personal information to third parties.

If we did sell personal information, you would have the right to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we would refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.

Children’s Right to Opt-In to the Sale of Personal Information

We do not sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:
In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:
In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please contact us at 800-592-9740 or email us at 2ndstreetusa_official@2ndstreetusainc.com with the subject “Minor Opt-Out.”

Our Collection and Disclosure of Personal Information

Sources from Which We Receive Personal Information
We receive personal information from the following categories of sources:

  • You, the consumer.
  • Fulfillment Providers.
  • Service Providers
  • Data Analytics Providers.
  • Social Networks.
  • Government entities.

Third Parties with Whom We Share Personal Information
We routinely share personal information with the following categories of third parties:

  • 2nd Street Companies.
  • Fulfillment Providers.
  • Data Analytics Providers.
  • Advertising Networks.
  • Service Providers.
  • Government entities.

Categories of Personal Information Collected, Disclosed, and Sold within the past 12 months.

Category of Personal InformationInformation CollectedSold in the Past 12 Months?Categories of Third Parties to Whom SoldDisclosed for a Business Purpose in Past 12 Months?Categories of Third Parties to Whom Disclosed
Individual IdentifiersPurchase Data;
Sale Data;
Newsletter Data;
Social Data;
Use Data;
Employee Data
NoNot ApplicableYesFulfillment Providers;
Service Providers;
Government Entities;
2nd Street Companies
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual.Purchase Data;
Sale Data; Newsletter Data
Social Data;
Use Data;
Employee Data
NoNot ApplicableYesFulfillment Providers;
Service Providers;
Government Entities;
2nd Street Companies
Characteristics of protected classifications under California or federal law.Purchase Data;
Sale Data;
Newsletter Data;
Employee Data
NoNot ApplicableYesFulfillment Providers;
Service Providers;
Government Entities;
2nd Street Companies
Commercial information.Purchase Data;
Sale Data;
Social Data;
Use Data;
Employee Data
NoNot ApplicableYesFulfillment Providers;
Service Providers;
Government Entities;
2nd Street Companies
Biometric information.Employee DataNoNot ApplicableYesService Providers
Internet or other electronic network activity.Use DataNoNot ApplicableYesService Providers
Geolocation data.Social Data;
Use Data
NoNot ApplicableYesService Providers
Audio, electronic, visual, thermal, olfactory, or similar information.Use DataNoNot ApplicableYesService Providers;
2nd Street Companies
Professional or employment-related information.Employee DataNoNot ApplicableYesService Providers;
2nd Street Companies
Education information.Employee DataNoNot ApplicableYesService Providers;
2nd Street Companies
Inferences drawn from any of the information identified above.NoneNoNot ApplicableYesNone

The above chart does not include information collected where your communications or transactions with us occur solely in the context of providing or receiving a product or service to or from a company, partnership, sole proprietorship, nonprofit, or government agency on whose behalf you are acting.

Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: 2ndstreetusa_official@2ndstreetusa.com with the subject “California Shine The Light Request” or 2nd Street, 7560 Melrose Avenue, Los Angeles, California 90046, Attention: Store Manager. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to 2ndstreetusa_official@2ndstreetusa.com with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Copyright © 2021 2nd Street USA, Inc. All rights reserved.