This California Privacy Notice (“CCPA Notice”) is provided pursuant to the California Consumer Privacy Act (“CCPA”) and supplements the information and disclosures contained in our Privacy Policy. In the event of a conflict between any other policy, statement, or notice, and this CCPA Notice, this CCPA Notice will prevail as to California consumers.
Our CCPA Notice applies to all individuals residing in California from whom we collect Personal Information, except for current/former employees and job applicants. If you are a current/former employee, job applicant, or if we collected your Personal Information in the context of your employment at another business and you have questions about how we use your Personal Information, please contact us as provided below.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
I. Collection, Use, and Disclosure of Personal Information
The chart below outlines the categories of “Personal Information” (as defined by the CCPA) that BWE may collect, use, and/or disclose for a business purpose consistent with applicable laws. These examples may vary depending on the nature of your interactions with us. More information about our specific practices can be found in our Privacy Policy.
| Category of Personal Information | Business Purposes for Collection, Use, or Disclosure | Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose |
|---|---|---|
| Identifiers, including name, title, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | • To provide and maintain our website, including to monitor the usage of the websites; • To maintain your accounts with us; • To provide you with the products and services that you request from us; • To communicate with you, including about our services, updates to our terms and policies, and to obtain your feedback; • To conduct advertising and marketing; • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes; and • To detect and prevent fraud against you and/or us. | • Data analytics providers; • Security providers; • Service providers who help us to place relevant advertisements; • Information technology vendors; and • Other service providers. |
| Personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, physical characteristics or description, address, telephone number, social security number, employment, payment information, or other financial information | • To provide and maintain our website, including to monitor the usage of the websites; • To provide you with the products and services that you request from us; • To maintain your accounts with us; • To communicate with you, including about our services, updates to our terms and policies, and to obtain your feedback; • To conduct advertising and marketing; • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes; and • To detect and prevent fraud against you and/or us. | • Data analytics providers; • Service providers who help us to place relevant advertisements; • Information technology vendors; and • Other service providers. |
| Commercial information, including records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | • To provide you with the products and services that you request from us; • To maintain your accounts with us; • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes; and • To detect and prevent fraud against you and/or us. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Internet or other electronic network activity information, including internet or other similar activity, browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement | • To provide and maintain our website, including to monitor the usage of the websites; • To maintain your accounts with us; • To conduct advertising and marketing; • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes; and • To detect and prevent fraud against you and/or us. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Characteristics of protected classifications under California or Federal law, including age, date of birth, gender, languages spoken, marital status, and racial or ethnic origin | • To provide and maintain our website, including to monitor the usage of the websites; and • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Geolocation data, including location inferred from your device IP address | • To provide and maintain our website, including to monitor the usage of the websites; and • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Sensory information, including consumer voicemails, and security camera footage | • To ensure the security of our premises and safety of individuals; • To provide you with customer service; and • To improve our services. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Professional or employment-related information, including your employer and title, professional licenses, and certifications | • To provide you with customer service; • To improve our services; and • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes. | • Data analytics providers; • Information technology vendors; and • Other service providers. |
| Personal Information that does not fit directly within one of the categories defined by the CCPA, including the contents of communications you send to us by phone, email, text etc. | • To communicate with you including about our services, updates to our terms and policies, and to obtain your feedback; • To provide you with customer service; • To improve our services; and • Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes. | • Information technology vendors; and • Other service providers. |
II. Disclosing Personal Information
In addition to the purposes for disclosing the categories of Personal Information identified above, we may also disclose Personal Information for the following business purposes:
1. Auditing related to a current interaction with you;
2. Detecting security incidents;
3. Identifying and repairing errors that impair functionality;
4. Short-term, transient use;
5. Contracting with service providers to perform services for us, including but not limited to providing analytic services and advertising services;
6. Undertaking internal research to improve our technologies and demonstration of those technologies;
7. Undertaking activities to maintain the quality of our services and to improve our services; and
8. For other purposes for which we provide specific notice at the time the information is collected.
We may also collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; in connection with disciplinary actions/investigations; or to conduct auditing. Likewise, we may use and disclose Personal Information to other parties in connection with the sale, assignment, merger, reorganization, or other transfer.
III. Sources of Personal Information
We may collect your Personal Information from the following sources:
• Directly from you or your authorized representatives. For example, when you provide us information online, through electronic forms, over the phone, or through paper documents. This may also include information from your computer or devices when you interact with our platforms, websites, and applications.
• Automatically through our websites. For example, directly and indirectly from activity and interactions on our websites, including www.bwe.com and affiliated sites, via cookies and other tracking technologies.
• From our service providers. For example, payment processors, vendors and suppliers, or other individuals and businesses.
• From other external sources. For example, data providers.
We may also collect publicly available information about you, including information that is lawfully made available to the general public from federal, State, or local government records.
IV. How Long We Keep Your Personal Information
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this CCPA Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
• Your Personal Information is reasonably required to protect or defend our rights or property; or
• We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
V. Submitting Requests Relating to Your Personal Information
If you are a California resident, you may exercise the following rights:
1. Right to know and access: You may request information regarding: (a) the categories of Personal Information we collect or disclose, (b) our business purposes for collecting or disclosing that information, (c) the categories of sources from which we collect that information, (d) the categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information, and/or (e) the specific pieces of Personal Information we collected about you;
2. Right to delete: Subject to certain limited exceptions, you have the option to ask BWE to delete Personal Information we have collected about you;
3. Right to opt-out of sales and sharing of Personal Information: We do not sell your Personal Information or share it for cross-contextual behavioral advertising, and as such we do not offer this right;
4. Right to correct inaccurate Personal Information: If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information; and
5. Right to limit use and disclosure of sensitive Personal Information: We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA, and as such we do not offer this right.
We will not discriminate against you for exercising your rights under the CCPA.
Note that your CCPA rights are subject to certain conditions and exceptions such as limitations on your right to know pursuant to legal privileges and according to Cal. Civ. Code Sec. 1798.105(d).
How to submit a request under the CCPA:
In order to exercise your rights, please email us at privacy@bwe.com and include “CCPA Request” in the subject line. You may also call us at 1 (866) 538-0488 and leave a voicemail detailing your request.
Please include in your request:
1. Your full name;
2. Your contact information (telephone number or email address on file with BWE).
If you are requesting information on behalf of another individual, you must include verification of identity for both yourself and the consumer, along with a copy of the consumer’s signed authorization.
We will endeavor to respond promptly to all requests.
VI. How to Contact Us
If you have any questions about how we handle your Personal Information, please contact us at:
Phone: 1 (866) 538-0488
Email: privacy@bwe.com
How can individuals with disabilities access these disclosures? Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of our CCPA Notice.