CA Privacy Policy

California Privacy Notice

Last updated: December 21, 2022

Please read this Privacy Policy carefully.

This Privacy Notice for California Residents (“Notice”) supplements the information contained in Liberty Diversified International Inc., its subsidiaries and affiliates’ (collectively, “we” or “LDI”) Website Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”).

We adopt this Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice applies to the personal information we collect from California residents who use our websites, communicate or request information from us, or otherwise interact with us. This Notice does not apply to personal information provided to or collected through use of the LDI application or from job applicants.

This Notice explains our collection, processing, and disclosure of “personal information” relating to California consumers. Specifically, this Notice applies to our processing activity when we are acting as a “business” under the CCPA, meaning that we control the purposes and means of processing your personal information.

Some of the personal information we collect may be exempt from some or all requirements under the CCPA. We may also receive your information in our capacity as a service provider to our customers or partners. In that case, questions relating to your personal information and your rights under California law should be directed to the customer or partner with whom you have a relationship.

Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any 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 does not include information that is:

• Lawfully made available from government records;
• Information we have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media;
• Made available by a person to whom the consumer has disclosed the information, if the consumer has not restricted the information to a specific audience;
• Lawfully obtained, truthful information that is a matter of public concern;
• Deidentified or aggregate consumer information; or
• Information excluded from the CCPA’s scope, including personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act.

In the past 12 months, LDI has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for business purposes.

Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.

How We Collect Your Information

Direct collection:

We collect information directly from you when you choose to provide it to us by filling out forms on our website, engaging in transactions with us, signing up to receive promotional or informational communications from us, using our services, communicating with us about our services, or otherwise directly providing the information to us.

Indirect and technology-based collection:

We also collect certain information from you indirectly when you visit, use, or navigate our website or mobile application. LDI collects certain identifiers, such as IP addresses, and internet and similar network activity, such as website usage data, using cookies, pixels, and passive tracking technologies, as described in our Privacy Policy.

Collection via social media:

We may collect personal data about social media users, including basic user profile information, user-generated content, associated metadata, contact details, and additional individual information published by the user. The type and scope of personal data obtained from social media platforms depends on the APIs, permissions, and administrative permissions granted by individuals, where applicable.

Third-party collection:

From time to time, we may obtain marketing or lead lists from third-party vendors. We use these, for example, to send you marketing communications.

Sensitive Personal Information

LDI does not collect “sensitive personal information” as defined by the CCPA for the purpose of inferring characteristics about California consumers. Accordingly, LDI treats any such information as “personal information” consistent with applicable provisions of the CCPA.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business or commercial purposes, as well as any other purposes set forth in our Privacy Policy:

• To fulfill or meet the reason you provided the information.
• To communicate with you and respond to your inquiries about our services and products.
• To provide, support, personalize, and develop our website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide support and respond to inquiries, including investigating and addressing concerns.
• To personalize your website experience and deliver relevant content and offerings.
• To help maintain the safety, security, and integrity of our website, products, services, databases, technology assets, and business.
• For testing, research, analysis, and product development.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To enforce our agreements and comply with legal or regulatory obligations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of LDI’s assets.

Applicable Retention Periods

For each category of personal information identified above, LDI will retain such information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this Notice. The criteria used to determine our retention periods include: for as long as we have an ongoing relationship with you; as required by a legal obligation to which we are subject; and as necessary to resolve disputes or enforce legal agreements.

Sale or Sharing of Personal Information

In the past 12 months, LDI has not “sold” any categories of personal information or “shared” any such information for the purposes of cross-context behavioral advertising. Likewise, LDI does not have actual knowledge of any sales or sharing of personal information regarding minors under 16 years of age.

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Request Information

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. Specifically, you may request that we disclose:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting your personal information.
• The categories of third parties with whom we disclose your personal information.
• The specific pieces of personal information we collected about you.
• If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.

2. Right to Data Portability

You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically.

3. Right to Request Deletion

You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

4. Right to Correct Inaccurate Information

If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of processing the personal information.

5. Right to Opt Out

Consumers in California have the right to opt out of the sharing of their personal information for cross-context behavioral advertising or the sale of personal information. Because LDI does not sell or share personal information, these rights are not available.

Exercising Your Rights

To exercise the rights described above, you — or someone authorized to act on your behalf — must submit a verifiable consumer request to us by either:

• Calling us at 1-800-421-1270.
• Emailing legal@libertydiversified.com with the subject line “CCPA Request.”

Your request must include your name, email address, mailing address, phone number, the nature of your inquiry, and the context in which we may have received your information.

Response Timing and Format

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing.

Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price, rate, level, or quality of goods or services.

Changes to This Notice

LDI reserves the right to amend this privacy notice at our discretion and at any time. When we make changes, we will post the updated notice on the website and update the “Last updated” date at the top of this document.

Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Data Sharing or Direct Marketing Purposes

California Civil Code § 1798.83, California’s Shine the Light Act, permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

Contact Information

If you have any questions or comments about this Notice, please contact us:

Phone: 1-800-421-1270
Email: legal@libertydiversified.com

Liberty Diversified International, Inc.
Attn: Legal Department
5600 North Highway 169
Minneapolis, MN 55428

If you need to access this policy in an alternative format due to having a disability, please contact legal@libertydiversified.com or 1-800-421-1270.

Effective date: January 1, 2020