Privacy Policy

Pursuant to the California Consumer Privacy Act (“CCPA“) and the California Privacy Rights Act (“CPRA“) (collectively, “California Privacy Law“), this Privacy Policy provides information about how CP Manufacturing, Inc. (“Company”) collects, stores, uses, transfers and otherwise processes personal information about California consumers (as defined by the CCPA). This Privacy Policy applies only to California consumers. For the purpose of this Privacy Policy, a “California consumer” is a natural person who resides in California. Please refer to Article 1 – Human Resources Consumers of this Privacy Policy for more information in the Human Resources context. Please refer to Article 2 – Non-Human Resource Consumers of this Privacy Policy for more information about other consumers.

Article 1 – Human Resources Consumers

Section 1. What is the Purpose of this Article?

The purpose of this Article is to inform job applicants, employees, owners, directors, officers, and contractors of the Company (collectively referred to as “employees” for the purposes of this Article), of the categories of Personal Information (as defined below) that we collect and the purposes for which we use such Personal Information.

Section 2. Collection and Use of Personal Information for Business Purposes

We collect information from our employees and job applicants 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 particular, the Company has collected the following categories of personal information from its employees or job applicants within the last twelve (12) months:

Category of Personal Information:

Identifiers

Examples:

A 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.

Collected:

YES

Sources:

Directly or indirectly from you
From third parties

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Third Parties Shared:

(a) Human resources information service providers and/or payroll service providers

(b) Financial investment service providers

(d) Insurance providers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples:

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.

Collected:

YES

Sources:

(a) Directly or indirectly from you
(b) From third parties

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Third Parties Shared:

(a) Human resources information service providers and/or payroll service providers

(b) Financial investment service providers

(d) Insurance providers

Sensitive Personal Information

Examples:

Social Security numbers; driver’s license, state identification card, and passport numbers; log-in details to a financial account or debit or credit card numbers (inclusive of the credentials needed to access the account or card); genetic data; and information about a workforce member’s health.

Collected:

Only as to Social Security numbers; driver’s license, and state identification card, as necessary.

Sources:

Directly or indirectly from you
(b) From third parties

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Third Parties Shared:

(a) Human resources information service providers and/or payroll service providers

(b) Financial investment service providers

(d) Insurance providers

Protected classification characteristics under California or federal law.

Examples:

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, reproductive decision-making, or any other category or activity protected by federal, state, or local laws, ordinances, or regulations.

Collected:

YES

Sources:

Directly or indirectly from you
(b) From third parties

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Third Parties Shared:

(a) Human resources information service providers and/or payroll service providers

(b) Financial investment service providers

(d) Insurance providers

Commercial information.

Examples:

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected:

Category of Personal Information:

Biometric information.

Examples:

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.

Collected:

YES

Sources:

Directly or indirectly from you

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Internet or other similar network activity.

Examples:

Browsing history, search history, personal social media activity, personal email, online transactions, information on a consumer’s interaction with a website, application, or advertisement.

Collected:

YES

Sources:

(a) Directly or indirectly from you
(b) From third parties

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Geolocation data.

Examples:

Physical location or movements.

Collected:

YES

Sources:

Payroll service providers

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Sensory data.

Examples:

Cameras located on Company property.

Collected:

YES

Sources:

Cameras located on Company property.

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Professional or employment-related information.

Examples:

Current or past job history or performance evaluations.

Collected:

YES

Sources:

Directly or indirectly from third parties

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples:

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.

Collected:

YES

Sources:

Directly or indirectly from third parties

Purpose:

Necessary for our legitimate interests

Third Parties Shared:

Human resources information service providers and/or payroll service providers

Inferences drawn from other personal information.

Examples:

Profile or personality tests reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected:

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

The Company obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete.
Indirectly from you. For example, from observing your interactions with company systems or our products or services.
Third Parties. For example, from vendors used for background checks.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, to conduct payroll and timekeeping activities, and administer benefits.
To investigate and help prevent fraud or otherwise ensure compliance with policies and procedures.
To provide you with support and to respond to your inquiries, including to investigate and address your 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 the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. The Company does not sell or seek to profit from employees’ or job applicants’ personal information.

Retention Schedule

To align with SB 807, Company maintains personnel files, along with other employee records and data for four (4) years. Similarly, the Company will retain collected employee personal information for four (4) years.

Section 4. How to invoke your California Privacy Rights?

You have the right to 1) know what information has been collected about you, 2) correct any inaccurate information or 3) delete any information that has been collected or maintained under this policy.

You may exercise your right(s) under the CCPA and by using one of the following methods:

Email: dataprivacy@cpgrp.com; or
Mail: Attn: Human Resources Department, CP Manufacturing, Inc., 6795 Calle de Linea, San Diego, CA 92154

Please be sure to include what right(s) you are seeking to invoke and provide what data or information your request is concerning so that your request can be properly and timely addressed.

Since we can only respond to a verified request, we may request information from you in order to confirm that you, or an authorized agent designated by you, are the one exercising your right as a consumer. We may request that you send your request through your account (if you have an account) or we may ask certain security questions to verify your identity before we respond to your request. You do not need to create an account with Company to exercise any of your individual rights (access, deletion, or opt-out of sale).

You have the right to designate an Authorized Agent. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

Section 5. Who can I Contact for Additional Information?

You can email Company’s Data Privacy team at: dataprivacy@cpgrp.com or through postal service at:

Attn: Legal Department
CP Manufacturing, Inc.
6795 Calle de Linea
San Diego, CA 92154

Phone: 619-477-3175

Article 2 – Non-Human Resource Consumers

Section 1. What is the Purpose of this Article?

California Privacy Law provides California consumers with certain rights regarding Personal Information about them. This Article describes how we collect, process, and disclose Personal Information about you during and after your relationship with us and explains your rights. If you are a California consumer and would like to exercise any of those rights under California Privacy Law, please see Section 5 below for more information on how to submit a request.

Section 2. What Categories of Personal Information Could Company Collect, Process, and Disclose and for what Purposes?

Category of Personal Information:

Identifiers

Examples:

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Collected:

YES

Sources:

Directly or indirectly from you

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Identify you and manage our relationship with you, including communicate with you, enable access to Company facilities and systems, deliver products/services and related information to you, meet compliance obligations, and manage safety.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders or transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or similar services

Third Parties Shared:

Vendors, service providers partners who such as providing technical infrastructure services, and other

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples:
A name, signature, address, telephone number

Collected:

YES

Sources:

Directly or indirectly from you

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Identify you and manage our relationship with you, including communicate with you, enable access to Company facilities and systems, deliver products/services and related information to you, meet compliance obligations, and manage safety.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders or transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or similar services

Third Parties Shared:

Vendors, service providers partners who such as providing technical infrastructure services, and other

Commercial information. A name, signature, address, telephone number

Example:

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected:

YES

Sources:

Directly or indirectly from you

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Identify you and manage our relationship with you, including communicate with you, enable access to Company facilities and systems, deliver products/services and related information to you, meet compliance obligations, and manage safety.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders or transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or similar services

Third Parties Shared:

Vendors, service providers partners who such as providing technical infrastructure services, and other

Internet or other similar network activity.

Example:

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected:

YES

Sources:

Directly or indirectly from you

Purpose:

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

Identify you and manage our relationship with you, including communicate with you, enable access to Company facilities and systems, deliver products/services and related information to you, meet compliance obligations, and manage safety.
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders or transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or similar services

Third Parties Shared:

Vendors, service providers partners who such as providing technical infrastructure services, and other

In the previous 12 months, we have not sold (as defined in California law) Personal Information to third parties.

The categories of third parties to whom we disclose your Personal Information, and the corresponding business purpose for the disclosure include: service providers and advertising partners, for purposes of providing marketing, personalization, and advertising services.

We do not collect Sensitive Personal Information, as defined under the CPRA, of non-HR consumers.

Section 4. What Rights Are Available to California Consumers?

Section 5. How Can California Consumers Invoke their Privacy Rights?

You may exercise your right(s) under the CCPA by using one of the following methods:

Email: dataprivacy@cpgrp.com; or
Mail: Attn: Legal Department, CP Manufacturing, Inc., 6795 Calle de Linea, San Diego, CA 92154

Please be sure to include what right(s) you are seeking to invoke and provide what data or information your request is concerning so that your request can be properly and timely addressed.

Section 6. Who can I Contact for Additional Information?

You can email Company’s Data Privacy team at: dataprivacy@cpgrp.com or through postal service at:

Attn: Legal Department
CP Manufacturing, Inc.
6795 Calle de Linea
San Diego, CA 92154

Phone: 619-477-3175