U.S. Privacy Policy

Last Updated: 5/15/2023

This Privacy Policy (“Privacy Policy” or “Policy”) explains how California Closet Company, Inc. and its corporate affiliates ( “we,” or “us,” or “our”) collect personal information based on your interactions with us online and offline, including on our websites, applications, forums, blogs (collectively the “Sites”), other online offerings, when we provide services or offer products online or offline (collectively, the “Services”). This Policy applies to our collection and use of personal information and describes rights you may have with respect to your personal information. By using our Sites and otherwise interacting with us, you agree to the terms of our Terms of Use, including this Policy.

This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.

Notice at Collection – Personal Information We Collect

We collect the following categories of personal information:

Personal identifiers: name, email address, address of the property for which service is requested or provided, your home or billing address, telephone numbers IP address
Protected class characteristics: age, sex/gender, marital status
Commercial and financial information: records of products or Services ordered or considered; other purchasing or consuming histories; and payment information. For franchise applicants, owners, and respective spouses, information about your assets, income, property and business ownership interests and operations, and other financial information you provide to us
Internet or other electronic activity information: your device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements
Geolocation information
Educational information: education history information provided by franchisee applicants
Professional information: job title, information about your employer and, for franchise applicants, owners, and respective spouses, employment and business ownership history and recommendations provided by references
Audio information: recordings of customer service calls for quality assurance purposes
Inferences drawn from Personal Information we collect

We have collected the same categories of personal information in the 12 months prior to the date of this Privacy Policy.

Notice at Collection – Purposes for Collection of Personal Information

We collect your personal information to provide you with the information you request and our Services. We use the information you provide us to contact you from time to time; to provide you with information about our business; for customer support; to deliver advertisements and marketing promotions and offers about products or Services we think may be of interest to you, including our Services and those of our affiliates; and to analyze the placement and effectiveness of our advertisements and other marketing efforts.

We also use personal information to monitor or improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.

For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.

Notice at Collection – Categories of Personal Information We Sell or Share and Related Information

When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of the word “sell” under certain state laws) or we may share them for purposes of cross-context behavioral advertising: personal identifiers (IP address) and internet or other electronic activity information.

These categories of personal information are sold to or shared for cross-context behavioral advertising to advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Services we provide. We do so by allowing third parties to place cookies or other trackers on our Sites that may collect information about your online activities over time and across different websites or applications. These parties may then use the information they collect to provide you with personalized content.. For more information about the use of cookies and trackers, see the section “Our Use of Cookies and Analytics” below.

We also sell the following categories of personal information to our affiliates, most of which are in the home improvement business, so they can offer their products and services to you: name, email address, physical address, commercial information such as purchasing history information.

We do not sell or share for cross-context behavioral advertising any of the other categories of personal information we collect.

To opt out of such sales and sharing of personal information, click here: https://preferences.calclosets.com/dont_sell

Notice at Collection – Retention Periods

We retain the categories of personal information we collect for the length of time necessary to provide our Service (including any warranty services) and to comply with legal obligations or to protect our legal rights.

Categories of Sources From Which We Collect Personal Information

We collect personal information directly from our customers, website users, and representatives of entities with which we do or may do business, data aggregators and data brokers.

We also collect personal information from franchisee applicants, owners, and respective spouses, franchises, and referrals provided about franchisee applicants, owners, and respective spouses.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information to create profiles about individuals or for any purposes other than providing our Services.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

The following chart describes the categories of personal information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:

Categories of Consumers’ Personal Information	Categories of Third Parties to Which We Disclosed Personal Information for Business Purposes
Personal identifiers: name, email address, address of the property for which service is requested or provided, home or billing address, telephone numbers, customer number, account password, IP address	Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, process franchisee applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and Services and those of our affiliates, provide analytics information, provide legal and accounting services, and host conferencing services. Subcontractors that perform specialized components of the Services we offer. Franchises.
Commercial information: records of products or Services purchased, ordered, returned, or considered; other purchasing or consuming histories; payment information. For franchise applicants, owners and their respective spouses, information about applicants’, owners’, and respective spouses’ assets, income, property and business ownership interests and operations, and other financial information provided	Service providers that manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, process franchisee applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products or Services and those of our affiliates, provide analytics information, and provide legal and accounting services. Franchises.
Internet or other electronic network activity information: device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements.	Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and Services and those of our affiliates, and provide analytics information.
Geolocation information	Service providers that advertise and market our products and services and those of our affiliates, provide analytics information.
Professional information: job title, information about your employer, franchisee applicants’ employment and business ownership history, and recommendations provided by references.	Service providers that manage business contact information and process franchisee applications,. Franchises.
Educational information: education history information provided by franchisee applicants.	Service providers that manage business contact information and process franchisee applications, Franchises.
Audio information: recordings of customer service calls for quality assurance purposes.	Service providers that manage customer information and provide customer service (including through our call center). Franchises.

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information for the following purposes: to provide our Services; manage customer, supplier and vendor accounts and relationships; process payments; verify customers’ identities; fulfill orders and transactions; engage in advertising and marketing of our Services and those of our affiliates; operate our IT systems and secure our systems; prevent fraud and other illegal activities; obtain professional advice about legal and accounting matters; evaluate and manage franchise applicants and owners.

Additional Information About How We May Disclose Personal Information and Purposes for Disclosures

We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Our Use of Cookies and Analytics

We and our service providers may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through the Services. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Sites and Services. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our Site.

We also allow third parties to use tracking technologies on our Sites for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our Sites. Some of these third parties use the tracking technologies to collect information about how you interact with other websites and advertisements across the Internet in order to provide advertising that is tailored to your interests and which may appear on our Sites or on other websites or platforms.

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.

We use Google Analytics to evaluate the use of our Sites. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a Site, what pages they visit when they do so, and what other websites they visited prior to visiting our Site. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.

Personal Information of Minors

Our products and Services are not directed to minors under the age of 18 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age.

Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals. We observe the Global Privacy Control signal.

Third Party Websites and Social Media Buttons

Our Sites may contain links to third party websites, including social media buttons that link to social media platforms. This Policy does not govern how those third parties or social media platforms collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

How We Keep Your Personal Information Secure

We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

Changes to This Policy

We will review and update this Policy from time to time. If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via email or a notice on our website.

Accessibility

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 800‑225‑2567.

Contact Us

If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at privacyrequests@calclosets.com or 833-973‑0699.

US State Data Privacy Rights

Laws in certain US states give residents of those states specific rights with respect to the personal information collected about them. See below for more information.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the following rights with respect to your personal information:

Your Right To Know About Personal Information We Collect

You can ask us for the following information with respect to the personal information that we’ve collected about you in the 12 months prior to our receipt of your request:

Specific pieces of personal information we have collected about you;
Categories of personal information we have collected about you;
Categories of sources from which such personal information was collected;
Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
The business or commercial purpose for collecting or selling your personal information.

Your Right To Request Deletion of Personal Information We Have Collected From You

Upon your request and subject to exceptions in the law, we will delete the personal information we have collected from you.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating it.

Your Right to Ask Us Not to Sell or Share Personal Information We Have Collected About You

With respect to those categories of personal information that we sell to third parties or share with third parties for the purposes of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.

Opt-out Preference Signals

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.

We recognize the Global Privacy Control signal and do so at the browser and device level and it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser on a specific device, we will recognize it for that browser and device only, and only with respect to the identifiers for that browser on that device. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the personal information disclosed to third parties for direct marketing purposes in the preceding calendar year. To make a request, please contact us at https://preferences.calclosets.com/privacy.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete or correct your personal information, or to ask a question, contact us at 1-833-973-0699 or click here. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can direct us not to sell your personal information or share it for purposes of cross-context behavioral advertising here. For such requests, we will comply no later than 15 business days after receipt of your request.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

Verification of Identity – Requests to Know, Delete or Correct

We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.

If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:

Requests to Know, Delete or Correct Personal Information: If the agent submits a request, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Requests to Opt Out of Sale or Sharing: If the agent submits a request to opt out of the sale of your personal information or the sharing of your personal information for purposes of cross-context behavioral marketing, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf.

To submit a request as an authorized agent, please contact us at privacyrequests@calclosets.com.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

VIRGINIA PRIVACY RIGHTS

The Virginia Consumer Data Privacy Act (“VCDPA”) grants Virginia residents the following rights with respect to their personal information we collect:

Right to Know: The right to confirm whether or not we are processing their personal information and to access such data
Right to a Copy: The right to a portable copy of the personal information we have collected from them
Right to Delete: The right to request deletion of their personal information that we have collected about them and to have such information deleted, subject to certain exceptions
Right to Correct: The right to ask that we correct inaccuracies in their personal information, taking into account the nature of personal data and purposes of processing such information
Right to Opt Out of Targeted Advertising: To the extent we engage in targeted advertising, the right to ask us to stop processing their personal information for such purposes

While Virginia law provides the right to opt out of the sale of personal information, we do not sell personal information consistent with the definition of “sale” under Virginia law.

Please note that for purpose of this section of this Policy, we consider “personal information” to have the same meaning as “personal data” as defined under the VCDPA.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete or correct, or to ask a question, contact us at 1‑833‑973‑0699 or click here. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can direct us not to process your personal information for purposes of targeted advertising here.

Verification of Identity – Requests to Know, Delete, Correct

We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.

If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.

Contact Us.
If you have any questions about our privacy practices or this Privacy Policy, please contact us at:
California Closet Company, Inc.
Attn: General Counsel
1414 Harbour Way S., Suite 1750
Richmond, CA 94804
privacypolicy@calclosets.com
1-800-225-2567

You may also contact our Data Privacy Officer:
Kenneth Martin
privacyrequests@calclosets.com

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