Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in Hinda’s Disclaimer and Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Hinda’s website, www.Hinda.com (“Website”), has collected the following categories of personal information from its consumers within the last twelve (12) months

Category	Examples	Collected
A. Identifiers.	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.	[YES]
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	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. Some personal information included in this category may overlap with other categories.	[YES]
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	[NO]
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES]
E. Biometric information.	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.	[NO]
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	[YES]
G. Geolocation data.	Physical location or movements.	[NO]
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	[NO]
I. Professional or employment-related information.	Current or past job history or performance evaluations.	[YES]
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	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.	[NO]
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	[NO]

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.

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

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

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

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• 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 personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• 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 Hinda’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Hinda about our Website users is among the assets transferred.

Hinda 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.

Sharing Personal Information

Hinda may 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 purpose except performing the contract. 

We share your personal information with the following categories of third parties:

• Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

[Category A: Identifiers.]

[Category B: California Customer Records personal information categories.]

[Category D: Commercial information.]

[Category F: Internet or other similar network activity.]

[Category G: Geolocation data.]

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Hinda disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• 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 sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Hinda delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at: us-privacy@hinda.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

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. To make such a request, please send an email to: us-privacy@hinda.com

Changes to Our Privacy Notice

Hinda reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Hinda collects and uses your information described below and in the Disclaimer and Privacy Policy, for your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: us-privacy@hinda.com

Privacy Shield Policy

This Privacy Shield Policy ("Policy") describes how Hinda collects, uses, and discloses certain data about an identified or identifiable individual that we receive in the United States (“U.S.”) from the European Economic Area ("EEA Personal Data") and Switzerland (“Swiss Personal Data”). In this Policy, countries that are members of the European Economic Area are collectively referred to as the “EU”. This Policy supplements the Hinda Privacy Policy located here, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as in the Hinda Privacy Policy.

Hinda recognizes that the EU and Switzerland have established strict protections regarding the handling of EU and/or Swiss Personal Data, including requirements to provide adequate protection for EU and/or Swiss Personal Data transferred outside of the EU and Switzerland. To provide adequate protection for certain EU and/or Swiss Personal Data relating to website visitors, customers, prospective customers, partners, vendors, third party suppliers and contractors that Hinda receives in the U.S., Hinda complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Hinda has certified to the Department of Commerce that it adheres to the Privacy Shield. Hinda adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this Policy and the Privacy Shield, the Privacy Shield shall govern.

For purposes of enforcing compliance with the Privacy Shield, Hinda is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield, see the U.S. Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review Hinda's Privacy Shield certification, see the U.S. Department of Commerce's list of Privacy Shield certified companies located at https://www.privacyshield.gov/list.

Types of EU and/or Swiss Personal Data Collected

Hinda collects EU and/or Swiss Personal Data (i) from individuals who visit our website and voluntarily provide their information, and (ii) from our customers, vendors, contractors and agents, including the following specific types of information:

• Contact information, including name, address, email address and phone number
• Professional and employment information
• Financial information

Hinda also collects certain data that may not specifically identify an individual but relate to an individual’s visit to our site, including information about equipment, browsing actions and usage patterns. This data is used for internal purposes only.

Purposes of EU and/or Swiss Personal Data Collection and Use

Hinda collects, uses and processes EU and/or Swiss Personal Data for the purposes of:

• Providing information about our products, services and events
• Providing products, services and support to our customers
• Administrative purposes relating to processing transactions with our customers
• Communicating with business partners, vendors, agents and contractors about business matters
• Analysis of information in order to improve business practices, products and services
• Conducting related tasks for legitimate business purposes
• Other purposes disclosed at the time of collection
• Compliance with legal requirements and protection of rights and property

Hinda will only process EU and/or Swiss Personal Data in ways that are compatible with the purpose for which Hinda collected the EU and/or Swiss Personal Data, or for purposes that the individual or entity providing the EU and/or Swiss Personal Data later authorizes. Before we use your EU and/or Swiss Personal Data for a purpose that is materially different than the purpose for which it was collected or that you later authorized, we will provide you with the opportunity to opt out. Hinda maintains reasonable procedures to help ensure that EU and/or Swiss Personal Data is reliable for its intended use, accurate, complete, and current.

We may collect, or our customers may provide to us when using Hinda services, certain EU and/or Swiss Personal Data that is regarded as “sensitive”. When we directly collect sensitive EU and/or Swiss Personal Data, we will obtain opt-in consent where the Privacy Shield requires, including if we disclose sensitive EU and/or Swiss Personal Data to third parties, or before we use sensitive EU and/or Swiss Personal Data for a different purpose than we collected it for or than the data subject later authorized.

Data Transfers to Third Parties

Third Party Agents or Service Providers. We may transfer EU and/or Swiss Personal Data to our third party agents or service providers that perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third party agents and service providers requiring them to provide the same level of protection that the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third party agents and service providers process EU and/or Swiss Personal Data in accordance with our Privacy Shield obligations and (ii) to stop and remediate any unauthorized processing. Under certain circumstances as specified within third party agreements, we may remain liable for the acts of our third party agents or service providers that perform services on our behalf for their handling of EU and/or Swiss Personal Data that we transfer to them.

Third Party Data Controllers. In some cases, we may transfer EU and/or Swiss Personal Data to unaffiliated third party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your EU and/or Swiss Personal Data to third party data controllers for the following purposes:

• To facilitate provision of services to Hinda customers, Hinda may provide EU and/or Swiss Personal Data to third party software and services companies whose products interact with Hinda products and services in certain instances where an Hinda customer is also a client of such third party.

We will only provide your EU and/or Swiss Personal Data to third party data controllers where you have not opted-out of such disclosures. We enter into written contracts with any unaffiliated third party data controllers requiring them to provide the same level of protection for EU and/or Swiss Personal Data that the Privacy Shield requires. We also limit their use of your EU and/or Swiss Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your EU and/or Swiss Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EU and/or Swiss Personal Data is protected with the same level of protection that the Privacy Shield requires.

Disclosures for National Security or Law Enforcement

Under certain circumstances, we may be required to disclose your EU and/or Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Hinda maintains reasonable and appropriate security measures to protect EU and/or Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the EU and/or Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU and/or Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information. If your EU and/or Swiss Personal Data was provided to us by an Hinda customer, we may facilitate your access to such data by directing you to the customer that provided your data to us.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your EU and/or Swiss Personal Data to us as noted below (Contact Us). We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU and/or Swiss Personal Data within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the European Union Data Protection Authorities (“DPAs”).

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have first taken the following steps: (1) raised your complaint directly with Hinda and provided us the opportunity to resolve the issue; (2) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration) at http://ec.europa.eu/justice/data-protection/files/annexes_eu-us_privacy_shield_en.pdf.

Contact Us

If you have any questions about this Policy or would like to request access to your EU and/or Swiss Personal Data, please contact us as follows:

Hinda 
Attn: Vance Primus - Data Compliance Department 
2440 W. 34^th St. 
Chicago, IL 60608, USA 
us-privacy@Hinda.com

Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.

Effective Date: October 10, 2019

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