Last updated February 22, 2024

We take your privacy seriously. This privacy notice for Western Products, a North Dakota Corporation referred to herein as (“Western Products,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services, such as when you:

Visit our website at https://www.westernproducts.com/, or any website owned or operated by Western Products and any of our subsidiaries or related companies, unless that site has its own privacy policy; or engage with us in other related ways, including any sales, marketing, or events (referred to herein as our “Services”).

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at customer.service@westernproducts.com.

SUMMARY OF KEY POINTS

It is important that you read the entire Policy. This summary provides key points from our privacy notice, but you can find more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact wit Western Products and our Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your privacy rights? If you choose to use our Services, the easiest way to exercise your privacy rights is by contacting us at customer.service@westernproducts.com. We will consider and act upon requests in accordance with applicable data protection laws.

Want to learn more about what Western Products does with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO CONNECTICUT RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO COLORADO RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO UTAH RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register to use our Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on our Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends upon the context of your interactions with us and our Services, the choices you make, and the products and features of our Services you use. The personal information we collect may include, but not be limited to, the following:

• • names;
  • phone numbers;
  • email addresses;
  • mailing addresses or other contact information;
  • passwords;
  • billing addresses; and
  • debit/credit card numbers & other payment information.

Sensitive Information. We do not process sensitive information such as race, ethnic origin, citizenship or immigration status, marital status, age, color, affiliations (religious, philosophical, or political), health, education, or personal ID numbers (license, social security, state ID, or passports).

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected.

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate our Services. This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes, but is not limited to:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings and information about your activity on our Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, which features you use and other actions you take), and device event information (such as system activity, error reports or crash dumps, and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access our Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access our Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of our Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention purposes, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending upon how you interact with our Services, including, but not limited to the following:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To fulfill and manage your orders. We may process your information to fulfill, track, and manage your orders, payments, returns, and exchanges made through our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below).

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for the purposes described below, including, but not limited to:

• • Sending users information about special offers and discounts on our products and services;
  • Developing and displaying personalized and relevant advertising content for our users;
  • Analyzing how our Services are used so we can improve them to engage and retain users; and
  • Supporting our marketing activities.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, to exercise or defend our legal rights, or to disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, but not limited to:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

• For investigations and fraud detection and prevention;

• For business transactions, provided certain conditions are met;

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

• For identifying injured, ill, or deceased persons and communicating with next of kin;

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province or the laws of the United States;

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

• If it was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced;

• If the collection is solely for journalistic, artistic, or literary purposes; and

• If the information is publicly available and is specified by the regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations, including, but not limited to, the situations described in this section and/or with the following third parties.

We may need to share your personal information in situations including, but not limited to, the following:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Third Parties. We may share your information with a third party if they perform services on our behalf, including, but not limited to shipping, and payment processing.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Except as otherwise provided herein, no purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access our Services within a secure environment. We are committed to protecting your information, but there is an expectation that you will assist in this effort. You should create a strong password and protect against unauthorized access to your password and computer. Be sure to sign off when finished using a shared computer and do not share your password with anyone.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We are committed to protecting children’s privacy on the Internet and do not knowingly solicit data from or market to children under 18 years of age. By using our Services, you represent that you are at least 18 years old or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at customer.service@westernproducts.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Any modification may affect your use of our Services.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you to send you Service-related messages that are necessary for the administration and use of your account, to respond to Service requests, or for other non-marketing purposes.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at customer.service@westernproducts.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice by revising this version of this privacy notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

California Consumer Privacy Compliance (CCPA and CPRA)

The California Code of Regulations defines a “resident” as:

(1) every individual who lives in the State of California for other than a temporary or transitory purpose, and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

“De-identified Data” is defined as information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer provided that the business:

• Takes reasonable measures to ensure that the information cannot be associated with a consumer or household;
• Publicly commits to maintain and use the information in de-identified form and not to attempt re-identification; and
• Contractually obligates recipients of the information to comply with this subdivision.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail, including, but not limited to, the following contexts:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

“Personal Information” does not include publicly available information lawfully made available to the general public from federal, state, or local government records.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at customer.service@westernproducts.com or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

The California Code of Regulations defines “sell, selling, sale, or sold” as 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 a third party for monetary or other valuable consideration.

Western Products has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Except as otherwise provided herein, Western Products will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Rights with Respect to Personal Data:

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to the following exceptions:

• To complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between us and the consumer;
• To ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes;
• To debug, identify, and repair errors that impair existing intended functionality of our Services;
• To ensure the exercise of free speech, and the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
• To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6; and
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us and compatible with the context in which the consumer provided the information.

Right to be informed — Request to know

In the event we collect personal information, you have a right to know:

• The categories of personal information that we collect;
• The sources from which the personal information is collected;
• The purpose for collecting, selling, or sharing personal information;
• The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose; and
• The specific pieces of personal information we collected about you.

In the event we sell personal information, or disclose it for a business purpose, you have the right to know:

• The categories of personal information that we collect;
• The categories of personal information that we sold, shared, or disclosed for a business purpose, if any;
• The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose; and
• The categories of personal information that we sold, shared, or disclosed for a business purpose, if any.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right of Portability

Upon request, you have the right to obtain your personal information, covering the 12-month period preceding the request, by mail or electronically without charge and in a readily usable format that allows you to transmit your information from one entity to another without hindrance.

In accordance with applicable law, we are not obligated to provide you with your personal information more than twice in a 12-month period.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out of the processing of your personal data for purposes of targeted advertising.
• You may request to opt out of the processing of your personal data for purposes of profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at customer.service@westernproducts.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“De-identified Data” means data that cannot reasonably be linked to an identified or identifiable natural person, or a device linked to such person.

“Sensitive data” means a category of personal data that includes:

• Personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status;
• The processing of genetic or biometric data for the purpose of uniquely identifying a natural person;
• The personal data collected from a known child; or
• Precise geolocation data.

“Sale of personal data” means the exchange of personal data for monetary consideration to a third party. “Sale of personal data” does not include:

• The disclosure of personal data to a processor that processes the personal data on behalf of the controller;
• The disclosure of personal data to a third party for purposes of providing a product or service requested by the consumer;
• The disclosure or transfer of personal data to an affiliate of the controller;
• The disclosure of information that the consumer (i) intentionally made available to the general public via a channel of mass media and (ii) did not restrict to a specific audience; or
• The disclosure or transfer of personal data to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the controller’s assets.

Under the VCDPA, the consideration must be monetary rather than the broader “monetary or other valuable consideration.”

If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. For example, we have the following responsibilities under the VCDPA:

• To limit the collection of personal data to what is adequate, relevant, and reasonably necessary in relation to the purposes for which such data is processed, as disclosed to you;
• To not process personal data for purposes that are neither reasonably necessary to nor compatible with the disclosed purposes for which the data is processed unless you give your consent;
• To establish, implement, and maintain reasonable administrative, technical, and physical data security practices to protect personal data;
• To not process personal data in violation of state and federal laws that prohibit unlawful discrimination or discriminate against you for exercising any of your consumer rights;
• To not process sensitive data without first presenting you with an option to opt-in; and
• To clearly and conspicuously disclose whether we sell personal data to third parties or process personal data for targeted advertising, and how to opt-out of such processing.

The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services. To find out more, please visit the following links:

• Personal data we collect

• How we use your personal data

• When and with whom we share your personal data

Western Products has not sold any personal data to third parties for business or commercial purposes. Except as otherwise provided herein, Western Products will not sell personal data in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data;
• Right to access your personal data;
• Right to correct inaccuracies in your personal data;
• Right to request deletion of your personal data;
• Right to obtain a copy of the personal data you previously shared with us; and
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at  customer.service@westernproducts.com, by visiting https://www.westernproducts.com/,  or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify yourself and your consumer request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension. In this time frame, we will either grant your request, or decline your request by providing the justification for declining to take action. The administrative costs of complying with the request or declining to act on the request will be provided to you free of charge, up to twice annually.

Right to Appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at customer.service@westernproducts.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.

13. DO CONNECTICUT RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Connecticut, you may be granted specific rights regarding access to and use of your personal information.

Connecticut Data Privacy Act Privacy Notice

Under the Connecticut Data Privacy Act (CTDPA):

“Consumer” means an individual who is a resident of this state. “Consumer” does not include an individual acting in a commercial or employment context.

“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable individual. “Personal data” does not include de-identified data or publicly available information.

“De-identified Data” means data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual or their device.

“Sensitive Data” means personal data that includes:

• Data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation, or citizenship or immigration status;
• consumer health data;
• The processing of genetic or biometric data for the purpose of uniquely identifying an individual;
• Personal data collected from a known child;
• data concerning an individual’s status as a victim of crime; and
• Precise geolocation data.

“Sale” means the exchange of personal data for monetary or other valuable consideration to a third party, but does not include:

• The disclosure of personal data to a processor that processes the personal data;
• The disclosure of personal data to a third party for purposes of providing a product or service requested by the consumer;
• The disclosure or transfer of personal data to an affiliate;
• The disclosure of personal data where the consumer directs to disclose the personal data or intentionally uses the business to interact with a third party;
• The disclosure of personal data that the consumer intentionally made available to the general public via a channel of mass media and did not restrict to a specific audience; and
• The disclosure or transfer of personal data to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction, or a proposed merger, acquisition, bankruptcy, or other transaction, in which the third party assumes control of any of the assets.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. For example, we have, the following responsibilities under the CTPDA:

• To limit the collection of personal data to what is adequate, relevant, and reasonably necessary in relation to the purposes for which such data is processed;
• To disclose to the consumer the purposes for which the data is processed;
• To not process personal data for purposes that are neither reasonably necessary to, nor compatible with, the disclosed purposes unless the consumer consents;
• To establish, implement, and maintain reasonable administrative, technical, and physical data security practices appropriate to the volume and nature of the personal data at issue;
• To not discriminate against a consumer for exercising a right by denying a good or service to the consumer, charging the consumer a different price or rate for a good or service, or providing the consumer a different level of quality of a good or service;
• To disclose whether or not we sell personal data or engage in targeted advertising and the way a consumer can exercise the right to opt out;
• To not process sensitive data without first presenting the consumer with an option to opt-in; and
• To conduct and document a data protection assessment for each processing activity that presents a heightened risk of harm to a consumer.

The information we collect, use, and disclose about you will vary depending on how you interact with Western Products and our Services. To find out more, please visit the following links:

• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data

Western Products has not sold any personal data to third parties for business or commercial purposes. Except as otherwise provided herein, Western Products will not sell personal data in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data;
• Right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data;
• Right to delete personal data provided by or obtained about you;
• Right to obtain a copy of the personal data you previously shared with us in a portable and, to the extent technically feasible, readily usable format; and
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

Exercise your rights provided under the Connecticut Data Privacy Act

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at customer.service@westernproducts.com, by visiting https://www.westernproducts.com/, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension. In this time frame, we will either grant your request, or decline your request by providing the justification for declining to take action. The administrative costs of complying or declining to act on the first request will be provided to you free of charge.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at customer.service@westernproducts.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

14. DO COLORADO RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Colorado, you may be granted specific rights regarding access to and use of your personal information.

Colorado Data Privacy Notice

Under the Colorado Privacy Act (CPA):

“Consumer” means an individual who is a Colorado resident acting only in an individual or household context. It does not include an individual acting in a commercial or employment context, as a job applicant, or as a beneficiary of someone acting in an employment context.

“Personal Data” means information that is linked or reasonably linkable to an identified or identifiable individual and does not include de-identified data or publicly available information. Identified or identifiable individual means an individual who can be readily identified, directly or indirectly, in particular by reference to an identifier such as:

“De-identified Data” means data that cannot reasonably be linked to an identified individual or an identifiable individual.

“Sensitive Data” means:

• Personal data that reveals racial or ethnic origin, religious beliefs, sexual orientation, citizenship or immigration status, and medical history, condition, treatment, or diagnosis;
• The processing of genetic personal data or biometric data, if the processing is for the purpose of identifying a specific individual; and
• Specific geolocation data.

“Sale” means the exchange of personal data for monetary consideration by a controller to a third party, but does not include:

• A disclosure of personal data to a processor who processes the personal data on the controller’s behalf;
• A disclosure of personal data to an affiliate;
• A disclosure of personal data to a third party if the purpose is consistent with a consumer’s reasonable expectations;
• The disclosure or transfer of personal data when a consumer directs the disclosure of the personal data or interacts with one or more third parties;
• A consumer’s disclosure of personal data to a third party for the purpose of providing a product or service requested by the consumer or a parent or legal guardian of a child;
• The disclosure of information that the consumer intentionally makes available to the general public via a channel of mass media and does not restrict to a specific audience; and
• A controller’s transfer of personal data to a third party as an asset that is part of a proposed or actual merger, acquisition, or bankruptcy.

Under the UCPA, the consideration must be monetary rather than the broader “monetary or other valuable consideration.”

If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. For example, we have the following responsibilities under the UCPA:

• To specify the purposes for which the categories of personal data are processed;
• To establish, implement, and maintain reasonable administrative, technical, and physical data security practices that are appropriate for the volume and nature of the personal data at issue considering the size, scope, and type of the controller’s business. The data security practices must be designed to protect the confidentiality and integrity of personal data and reduce reasonably foreseeable risks of harm to consumers from personal data processing;
• To not discriminate against a consumer for exercising a right by denying a good or service to the consumer, charging the consumer a different price or rate for a good or service, or providing the consumer a different level of quality of a good or service;
• To clearly and conspicuously disclose the manner in which a consumer may exercise the right to opt out of the sale or processing for targeted advertising; and
• To not process sensitive data without first presenting the consumer with an opportunity to opt out.

The information we collect, use, and disclose about you will vary depending on how you interact with Western Products and our Services. To find out more, please visit the following links:

• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data

Western Products has not sold any personal data to third parties for business or commercial purposes. Except as otherwise provided herein, Western Products will not sell personal data in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

• Right to confirm whether or not we are processing your personal data and to access that data;
• Right to delete your personal data that you have provided directly to us;
• Right to obtain your personal data in a portable and readily usable format that allows you to transmit the data without impediment, where the processing is carried out by automated means; and
• Right to opt out of the processing of your personal data for purposes of targeted advertising and the sale of personal data.

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at customer.service@westernproducts.com.