California Consumer Privacy Act
Effective Date: 26 June 2020
Last Reviewed On: 26 June 2020
This Notice applies to all website visitors, users, consumers, customers, and any others who reside in the State of California (“consumers” or “you”) and whose personal information is collected by Dematic. This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. This Notice, as outlined below, may be modified from time to time and we reserve the right to amend this Notice at any time and at our discretion. When changes are made to this Notice, we will provide you with notice of the same via the above referenced website and update the Notice’s Effective Date. Your continued use of our website, products and services following notification of changes constitutes acceptance of such changes.
3. Policy and Procedures Review
The Notice and related procedures will be reviewed every twelve (12) months or as necessary.
4. Personal Information
Dematic collects and maintains different types of personal 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 or device (“personal information”) in accordance with applicable law. The CCPA sets out eleven categories of personal information as follows:
- Identifiers. For example, real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). For example, a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Protected classification characteristics under California or federal law. For example, race (which includes historically associated traits, such as hair styles and protective hair styles, e.g., braids, locks, and twists), religious creed (which includes religious dress and grooming practices), color, national origin (which includes, but is not limited to, national origin groups and aspects of national origin, such as height, weight, accent, or language proficiency), ancestry, physical disability, mental disability, medical condition, genetic information, marital status, sex (which includes pregnancy, childbirth, breastfeeding, and related medical conditions), gender, gender identity, gender expression, age, sexual orientation, military or veteran status (including state and federal active and reserve members as well as those ordered to duty or training), immigration/citizenship status or related protected activities (which includes undocumented individuals and human trafficking), protected medical leaves, domestic violence victim status, political affiliation, or any other category or activity protected by federal, state, or local laws, ordinances, or regulations.
- Commercial information. For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information. For example, genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Internet or other similar network activity. For example, browsing history, search history, personal social media activity, personal email, online transactions, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation data. For example, physical location or movements.
- Sensory data. For example, audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information. For example, current or past job history, salary information, payment history, or performance evaluations.
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). For example, education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Inferences drawn from other personal information. For example, profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
5. Collection and Sharing of Personal Information
Dematic may collect the following categories of personal information from the listed categories of sources. We may also disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purse expect performing the contract.
- Identifiers. This information is collected directly from you for the purpose of validating completed work activities and to support notifications generated by certain products. This information is shared with our customers who own the projects on which you work and third party data hosting centers.
- Personal information categories listed in the California Customer Records statute. This information is collected directly from you for the purpose of validating completed work activities and to support notifications generated by certain products. This information is shared with our customers who own the projects on which you work and third party data hosting centers.
- Internet or other similar network activity. This information is collected directly and indirectly from you through your use of our products. The information is collected to save user preferences and use history and is shared with third party data hosting centers.
- Geolocation data. This information may be collected by Dematic from you for the purpose of tracking completed work activities and to support notifications generated by certain products. This information may be shared with our customers who own the projects on which you work and third party data hosting centers.
6. Uses of Personal Information
In addition to the uses described above, Dematic may also use your personal information for the following purposes:
- To fulfill or meet the reason you provided the information. For example, to monitor work, provide support of our customer’s system and maintenance of Dematic’s customer’s systems.
- To provide product support and to respond to inquiries, including to investigate and address customer concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our systems, services, databases and other assets.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- 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 sale or transfer of some or all of Dematic’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Dematic’s about our users is among the assets transferred.
7. Sales of Personal Information
In the preceding twelve (12) months, Dematic has not sold personal information.
8. Your Rights and Choices Under the CCPA
The CCPA provides California residents with certain rights regarding their personal information as described below.
- The right to know about personal information collected. 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 twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you within the time allotted under the CCPA, the relevant information, which may include:
- 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 or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.
- The right to request deletion of personal information. Subject to certain exceptions, you have the right to request we delete your personal information that we collected about you and retained. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you or our customers.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
9. Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us by either:
- Calling us toll-free at: 1 (877) 725-7500
- Emailing us at: DematicDPO@dematic.com
- Writing us at: Dematic Corp., 507 Plymouth Ave., NE, Grand Rapids, MI 49505, Attn: Legal Department (Privacy – CCPA)
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please complete the following form or provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must include the following information: name, contact information (address, telephone number, and email). We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will work to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to 45 additional calendar days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
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, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
11. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Dematic does not disclose personal information to third parties for direct marketing use. If you have questions about this right or our policies, please contact us at: DematicDPO@dematic.com
12. Questions About This Notice
If you have any questions or comments about this Notice, the ways in which Dematic collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:
- Calling us toll-free at: 1 (877) 725-7500
- Emailing us at: DematicDPO@dematic.com
- Writing us at: Dematic Corp., 507 Plymouth Ave., NE, Grand Rapids, MI 49505, Attn: Data Privacy Officer / Legal Department